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ce Jane Doe 1, as well as other Members of the Class, to engage in commercial sex acts. 379. JP Morgan, through its employees and agents (including Staley), actively participated in the sex trafficking conspiracy and led Jane Doe I, as well as other Class Members, to believe that they would be rewarde
ex acts, through providing financial support for the Epstein sex-trafficking venture. A number of those acts were committed by JP Morgan's officer, Jes Staley, acting within the actual and apparent scope of his employment to further JP Morgan's interests. 435. Among the many overt acts intentionally comm
rentta641 PkWCW/MDEM WOmelDWO722 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 9 of 76 the property 49 Zorro Ranch Road in Stanley, New Mexico, which was transferred to it in or about December 2011, shortly after it was incorporated. 39. Defendant Maple, Inc. is a Virgin Islan
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
6-1 Filed 01/10/23 Page 10 of 77 GVI v. Estate of Jeffrey Epstein GVI's Second Amended Complaint Page 9 of 76 the property 49 Zorro Ranch Road in Stanley, New Mexico, which was transferred to it in or about December 2011, shortly after it was incorporated. 39. Defendant Maple, Inc. is a Virgin Islan
t 16 Filed 01/10/23 Page 13 of 34 III. Head of JP Morgan's Private Bank Had Close Personal Relationship With Epstein 52. Former senior executive, Jes Staley ("Staley"), developed a close relationship with Epstein when Staley was the head of JP Morgan's Private Bank, which is a segment of JP Morgan's bus
/10/23 Page 13 of 34 III. Head of JP Morgan's Private Bank Had Close Personal Relationship With Epstein 52. Former senior executive, Jes Staley ("Staley"), developed a close relationship with Epstein when Staley was the head of JP Morgan's Private Bank, which is a segment of JP Morgan's business ded
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,
t is also allegedly investigating his involvement in this activity." • "He is also an alleged personal associate of the CEO of the Investment Bank (Jes Staley)" • "AML Operations went to a [Private Bank] risk meeting late last week requesting that we exit this relationship." • "whether Epstein if furth
ding Dimon review)." III. Head of JP Morgan's Private Bank Had Close Personal Relationship With Epstein 52. Former senior executive, Jes Staley ("Staley"), developed a close relationship with Epstein when Staley was the head of JP Morgan's Private Bank, which is a segment of JP Morgan's business ded
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
be very disappointed." Please respond to the alleged statement about Barclays' culture by the bank's compliance employee. BARCLAYS CHIEF EXECUTIVE JAMES STALEY'S COMPLIANCE IMPROPRIETIES 26. Barclays new chief executive James "Jes" Staley was rebuked and personally fined for trying to unmask the authors of t
letters received by Barclays that questioned the fitness of a prospective hire. More recently, Barclays said that UK authorities are investigating Staley's ties to sex offender, the late Jeffrey Epstein. Please comment on these two incidents involving the chief executive of Barclays and if the bank t
tness of the bank's compliance culture. BARCLAYS AND THE FACILITATION OF TRANSACTIONS FOR THE ROTENBERGS 27. Is it true that Barclays reported to FinCEN at the end of November 2016 that from March 2012 to March 2016 it had done transactions worth $728,288.65 to offshore companies Stormont Systems Lt
clear that if she did not abide then she would suffer serious financial and reputational harm), through the end of 2013. 115. James "Jes" Staley ("Staley"), the then-head of JP Morgan's private banking division, was a regular visitor of Epstein's during that period of time, through and beyond 2013, a
e an intentional decision to keep Epstein on as a client. 217. JP Morgan, including its CEO Jamie Dimon and the highest levels of the bank, knew of Jes Staley's personal involvement with Epstein and yet still allowed Staley to remain a decision maker for JP Morgan on Epstein accounts. 218. Even before the s
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
OOCHENKO Mailing address (number and street or PC box; see instructions) Apartment number 288 WEST 4TH ST laity, village, or post otnce NEW YORK Stale NY ZIP code 10014 i axpayer s e-mail address 768042 10.27.17 Department of Taxation and Finance Tips for Estimated Tax Did you know? You can pay
cement Network (FinCEN) I May 2015 Record of Authorization to Electronically File FBARs (See instructions below for completion) Do not send to FinCEN. Retain this form for your records. ANASTAS20170001 The fomi 114a may be digitally signed Part I I Persons who have an obligation to file a Report
Entities connected to both Jes Staley and FinCEN

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Prince Andrew
PERSONLeon Black
PERSON
Marc Rich
PERSONDarren Indyke
PERSON
Woody Allen
PERSON
Richard Kahn
PERSON
Ghislaine Maxwell
PERSON
Joe Biden
PERSON
George Mitchell
PERSON
Boris Nikolic
PERSON
Condoleezza Rice
PERSON
Alan Dershowitz
PERSON
John F. Kennedy
PERSON
Robert Gates
PERSON
United States
LOCATION
Donald Trump
PERSON
Reid Weingarten
PERSON
Stephen Hawking
PERSON