An email from Sullivan & Cromwell attorney Nicolas Bourtin to federal prosecutors alerting them that TD Bank filed a Suspicious Activity Report (SAR) on approximately $30 million in accounts linked to Jeffrey Epstein entities, seeking guidance before closing the accounts.

This October 1, 2019 email represents TD Bank's formal notification to the Southern District of New York prosecutors about suspicious Epstein-linked accounts. Filed approximately three months after Epstein's arrest and two months after his death, the SAR covered entities associated with Epstein holding roughly $30 million. The bank, represented by prominent white-collar defense attorney Nicolas Bourtin of Sullivan & Cromwell, wanted to close all accounts immediately but sought prosecutorial guidance in case the government intended to seize or freeze the funds as part of ongoing investigations.

Key Highlights

• •TD Bank filed a SAR identifying approximately $30 million in accounts linked to Epstein-associated entities
• •The bank proactively contacted prosecutors before closing accounts to allow potential government action
• •Nicolas Bourtin, a former federal prosecutor and Sullivan & Cromwell partner who has represented major banks including TD Bank, JPMorgan Chase, and Goldman Sachs, sent the notification
• •This was part of a broader pattern where multiple banks filed SARs on Epstein accounts after his July 2019 arrest, including JPMorgan's September 2019 report flagging over $1 billion in suspicious transactions

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