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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
institutions act as a critical line of defense against illegal financial transactions in an ever changing and interconnected financial network. 2. The Federal Bank Secrecy Act ("BSA") requires financial institutions to have adequate anti-money laundering ("AML") policies and systems in place. New York State law requires f
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
n in 2013. C. JP Morgan's Role in the Sex-Trafficking Venture 1. Banking laws and regulations exist to prevent funding of criminal ventures. 116. The Federal Bank Secrecy Act ("BSA") requires financial institutions 30 EFTA00162150 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 31 of 130 to have adequate anti-m
York, Florida, New Mexico, New Jersey, Massachusetts, the U.S. Virgin Islands, and elsewhere, and in foreign commerce to places abroad, especially Eastern Europe. 121. At all times relevant to this complaint, the Epstein sex-trafficking venture was a group of two or more individuals associated in fact, even
al behavior in participating in Epstein's sex-trafficking venture. 2. Banking Regulations Exist to Help Prevent Funding of Criminal Ventures. 178. The Federal Bank Secrecy Act ("BSA") requires financial institutions to have adequate anti-money laundering ("AML") policies and systems in place. New York state law requires f
Entities connected to both Eastern Europe and The Federal Bank Secrecy Act

Jeffrey Epstein
PERSON
United States
LOCATION
Marc Rich
PERSON
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSON
Jean-Luc Brunel
PERSON
New York
LOCATION
Lesley Groff
PERSONNadia Marcinkova
PERSONFBI
ORGANIZATION
Sarah Kellen
PERSON
JPMorgan Chase
ORGANIZATION
Jes Staley
PERSON
Deutsche Bank
ORGANIZATION
Southern District of New York
ORGANIZATION
Financial Services
ORGANIZATIONSouthern Trust Company
ORGANIZATION
Frankfurt
LOCATION
FinCEN
ORGANIZATIONthe New York Stock Exchange
ORGANIZATION