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sexual conduct, sex trafficking, and forced labor. 29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to many other Epstein v
activity, it is required to report that information within 30 days to the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN"). The reporting requirement ensures that the government is able to monitor and act when alerted to potential illegal conduct. 18. Appendix F of t
Mr. Epstein was involved with Eastern European women in particular and that a modeling agency he helped fund brought "young girls . . . often from Eastern Europe" to the U.S. on Mr. Epstein's private jets. Deutsche Bank Onboarded Epstein in 2013 16. In early 2013, Mr. Epstein, who had been banking with one
ists, and transnational organized criminals." 24 EFTA00151518 79. On July 15, 2014, the U.S. Treasury's Financial Crimes Enforcement Network ("FinCEN") named FBME a foreign financial institution of primary money laundering concern pursuant to Section 311 of the USA PATRIOT Act (the "311 Designatio
reign commerce between the United 23 EFTA00162143 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 24 of 130 States and Europe, especially Eastern Europe. 88. At all times relevant to this complaint, the Epstein sex-trafficking venture was a group of two or more individuals associated in fact, even
failed to file with the federal government the required SARs that financial institutions must file with the Financial Crimes Enforcement Network ("FinCEN") whenever there is a suspected case of money laundering or fraud. Timely filing of these reports is required by the Bank Secrecy Act and related l
sexual conduct, sex trafficking, and forced labor. 29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to marry other Epstein
s enforcement of the TVPA, JP Morgan failed to timely file with the federal government the required SARs that financial institutions must file with FinCEN whenever there is a suspected case of money laundering or fraud. Timely filing of these reports is required by the Bank Secrecy Act and related law
sexual conduct, sex trafficking, and forced labor. 29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to many other Epstein v
activity, it is required to report that information within 30 days to the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN"). The reporting requirement ensures that the government is able to monitor and act FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual,
Entities connected to both Eastern Europe and FinCEN

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
United States
LOCATION
Donald Trump
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSONDarren Indyke
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
Samantha Power
PERSON
Abraham Lincoln
PERSON
Stephen Hawking
PERSON
U.S. Virgin Islands
LOCATION
George W. Bush
PERSON
Julie K. Brown
PERSON
Barack Obama
PERSON
George Mitchell
PERSON
Jean-Luc Brunel
PERSON