JPMorgan Chase Bank served as Jeffrey Epstein's primary banking institution from approximately 1998 until 2013, facilitating financial transactions that enabled his sex trafficking operations over a fifteen-year period. The relationship, which involved as many as 55 accounts in Epstein's name, shell companies, and entities connected to his associates, became the subject of litigation and regulatory scrutiny after revelations that the bank failed to report suspicious activity despite internal warnings about Epstein's criminal conduct. In 2023, JPMorgan agreed to pay $290 million to settle a class action lawsuit brought by Epstein's victims and an additional $75 million to settle claims by the U.S. Virgin Islands government.
Scope of the Banking Relationship#
JPMorgan Chase maintained an extensive banking relationship with Epstein that encompassed multiple types of accounts and financial services. According to shareholder derivative litigation filed in May 2023, Epstein operated as many as 55 accounts through JPMorgan during his tenure as a client, including accounts in his own name, accounts held by shell companies and purported non-profit entities, and accounts in the names of his victims, associates, and recruiters.
The relationship formally began around 1998, when Jes Staley, then head of JPMorgan's Private Banking division, was reportedly told to "get to know" Epstein as an important client. Epstein's accounts facilitated massive cash withdrawals and wire transfers; during certain periods, Epstein reportedly withdrew up to $80,000 in cash multiple times a month, and once withdrew more than $750,000 in cash in a single year.
The banking relationship extended beyond traditional deposit accounts. Epstein maintained brokerage accounts across asset classes and received investment advisory services from the firm. A 2011 Know Your Customer (KYC) report indicates Epstein was "an active brokerage client across asset classes currently covered by the Firm's GIO desk" and noted that he "has been an investment advisor for numerous high net worth clients and also a personal investor."
Key Personnel and Executive Knowledge#
Jes Staley
James "Jes" Staley served as the primary JPMorgan executive managing Epstein's relationship with the bank. Staley held various senior positions during Epstein's time as a client: head of Private Banking (1999-2001), CEO of Asset Management (2001-2009), and CEO of the Investment Bank (September 2009-January 2013). The amended shareholder derivative complaint alleges that Staley and Epstein "shared a deep personal friendship" and exchanged approximately 1,200 emails between 2008 and 2013, including pictures of young women in seductive poses.
Emails in the archive show frequent, sometimes cryptic communication between Staley and Epstein. In one June 2010 email, Staley wrote to Epstein at 1:48 AM: "R u up?". Another email shows Staley writing "I need your help. I will call shortly" in the early morning hours. The nature of these communications and their timing raised questions about the extent of Staley's personal involvement with Epstein beyond professional banking duties.
Mary Erdoes
Mary Callahan Erdoes, who became CEO of JPMorgan's Asset & Wealth Management division in September 2009, also had knowledge of Epstein's conduct and the bank's relationship with him. The shareholder derivative complaint alleges that Erdoes "paid numerous visits to Epstein's home and has admitted that she and JP Morgan knew of Epstein's abuses by 2006." Following a September 2006 New York Times article about Epstein's arrest for soliciting a minor for prostitution, Erdoes reportedly observed sarcastically in internal emails that Epstein was "a lovely guy to work with".
Jamie Dimon
The extent of CEO Jamie Dimon's direct involvement remains contested. An August 2008 internal document referenced Epstein's "$120 million with JP Morgan being in question 'pending Dimon review,'" suggesting Dimon's personal involvement in decisions regarding the Epstein relationship. An employee wrote that she "would count Epstein's assets as a probable outflow for '08 ($120mm or so?) as I can't imagine it will stay (pending [Jamie] Dimon review)." However, JPMorgan and Dimon have denied that he had direct knowledge of Epstein's criminal activities during the banking relationship.
Stephen Cutler
JPMorgan's General Counsel Stephen Cutler played a key role in internal discussions about maintaining the Epstein relationship despite mounting concerns. In July 2011, Cutler emailed Staley and Erdoes writing: "This is not an honorable person in any way. He should not be a client". The following day, Cutler emailed Erdoes again, describing Epstein as "Not a person we should do business with, period". Despite these explicit recommendations from the bank's top legal officer, Epstein's accounts remained open until 2013.
Internal Warnings and Red Flags#
JPMorgan's internal compliance and risk management personnel raised repeated concerns about Epstein as a client, particularly after his 2006 arrest and 2008 guilty plea for solicitation of a minor for prostitution.
2006 Arrest
When Epstein was arrested in Florida in 2006 on charges related to soliciting a minor, JPMorgan executives internally acknowledged awareness of his conduct. The September 2006 arrest triggered internal emails among bank executives, including Erdoes's sarcastic comment about Epstein being "a lovely guy to work with."
2008 Guilty Plea and High-Risk Designation
Following Epstein's 2008 guilty plea to felony charges of solicitation of a minor for prostitution, JPMorgan labeled Epstein a "high-risk" client. A mid-July 2008 internal risk function memorandum documented that "Catherine [Keating, the CEO of the Company's Private Bank] will go back to Jes [Staley] to tell him we are uncomfortable with Epstein." Despite this discomfort expressed by senior risk management personnel, the relationship continued for another five years.
2010 Concerns
In mid-2010, a risk management division employee referred to "new allegations of an investigation related to child trafficking" and asked whether JPMorgan was "still comfortable with this client who is now a registered sex offender". Other compliance employees decided that Epstein "should go." Paradoxically, in December 2010, JPMorgan granted Epstein a new $50 million line of credit.
2011 MC2 Model Management Report
An internal March 2011 report provided explicit evidence of suspected sex trafficking. The report explained that "MC2 Model Management and Jeffrey Epstein engaged in racketeering that involved luring in minor children for sexual play for money" and noted that MC2 Model Management's owner was a "frequent passenger on Epstein's private jet and often visited Epstein in jail." In 2011, JPMorgan employees also explicitly questioned whether a previous payment to a "model management" agency was "payment for services as a procurer".
July 2011 General Counsel Warnings
The most forceful internal warnings came from General Counsel Stephen Cutler in July 2011. Despite Cutler's unambiguous recommendations that Epstein "should not be a client" and was "not a person we should do business with, period," the accounts remained operational until 2013.
Failure to File Suspicious Activity Reports#
A central allegation in subsequent litigation against JPMorgan is that the bank consistently failed to file Suspicious Activity Reports (SARs) as required under the Bank Secrecy Act and anti-money laundering regulations, despite having substantial reasons to suspect criminal activity. The shareholder derivative complaint alleges that JPMorgan "consistently failed to file suspicious activity reports ('SARs') that it was required to file when it suspected potential criminal activity—as it clearly did."
This failure occurred despite obvious red flags, including:
- Epstein's status as a convicted sex offender
- Extraordinarily large and frequent cash withdrawals (up to $80,000 multiple times per month)
- Payments to "modeling agencies" suspected to be involved in sex trafficking
- Wire transfers to individuals identified as victims or recruiters
- Internal compliance warnings about possible "payment for services as a procurer"
The failure to file SARs persisted throughout Epstein's entire relationship with the bank from 1998 to 2013, and even continued for years after JPMorgan terminated his accounts in 2013, lasting until Epstein's final arrest in 2019. This prolonged failure meant that law enforcement was deprived of information that could have led to earlier intervention in Epstein's ongoing criminal conduct.
Termination of the Relationship (2013)#
In 2013, JPMorgan finally terminated its banking relationship with Epstein, though the decision came years after internal compliance personnel had recommended doing so. A July 2013 KYC report states: "Jeffrey Epstein was asked to exit the firm in August of 2013. The accounts are in the process of moving to another bank and should be closed out by year-end".
The KYC report provides details about the exit process, noting that Epstein's accounts were actively being transitioned to another financial institution. The report continued to designate Epstein as "High Risk" due to "Derogatory information - Jeffrey Epstein personally is flagged as High Risk due to felony conviction." The document detailed Epstein's 2008 conviction: "Several newspaper articles were found that detail the indictment of Jeffrey Epstein in Florida on felony charges of soliciting underage prostitutes. Jeffrey Epstein served 13 months in jail... Jeffrey Epstein is required to register as a sex offender."
The timing of the termination is significant: it came approximately five years after Epstein's guilty plea, four years after internal risk personnel had questioned the relationship, and two years after the bank's General Counsel explicitly recommended ending it. The amended complaint alleges that JPMorgan "continued doing business with Epstein personally until 2013, and potentially continued to engage with Epstein related entities until his death in jail in 2019."
Prior Regulatory and Criminal History#
JPMorgan's failure to properly monitor the Epstein accounts occurred against a backdrop of broader institutional failures in anti-money laundering compliance. The shareholder derivative complaint notes that JPMorgan's failure to file SARs and comply with AML regulations was "nothing new for JP Morgan."
In 2013, both the Office of the Comptroller of the Currency (OCC) and the Federal Reserve accused JPMorgan of failing to comply with federal AML laws and regulations, including failures to file timely SARs. JPMorgan was hit with a $350 million sanction in 2014 due to continuing AML compliance failures. Most seriously, the bank pleaded guilty in 2014 to two felony counts relating to failures to comply with AML rules, including the failure to file SARs.
A 2014 Deferred Prosecution Agreement between JPMorgan and the U.S. Department of Justice, stemming from the bank's role in facilitating Bernie Madoff's Ponzi scheme, required the bank to implement extensive reviews of past SAR filings and enhance its compliance systems. This agreement was in effect during the final years of Epstein's relationship with the bank, yet apparently did not result in retrospective filing of SARs related to Epstein's accounts.
Bear Stearns Acquisition Connection#
JPMorgan's relationship with Epstein predated but was complicated by its 2008 acquisition of Bear Stearns, which had its own history with Epstein. A 2011 settlement agreement reveals that entities associated with Epstein—including Financial Trust Company, Inc., The C.O.U.Q. Foundation, Inc., and Epstein personally—had made investments in Bear Stearns hedge funds that collapsed in 2007-2008. The settlement, which involved "The Bear Stearns Companies Inc. (n/k/a The Bear Stearns Companies LLC), Bear, Stearns & Co. Inc. (n/k/a J.P. Morgan Securities LLC)," resulted in a $9.2 million payment to resolve disputes arising from these investments.
The settlement agreement shows that by 2011, former Bear Stearns entities had become JPMorgan entities, creating legal continuity between Bear Stearns's pre-acquisition relationship with Epstein and JPMorgan's post-acquisition relationship. This meant JPMorgan had inherited not only Bear Stearns's assets and business lines, but also its exposure to Epstein-related litigation and regulatory risk.
2023 Litigation and Settlements#
Jane Doe Class Action
In 2022, a victim identified as "Jane Doe 1" filed a class action lawsuit against JPMorgan Chase Bank on behalf of herself and other victims of Epstein's sex trafficking. The lawsuit alleged that JPMorgan knowingly facilitated Epstein's sex trafficking operation by providing banking services despite awareness of his criminal conduct and failing to file required suspicious activity reports.
After extensive litigation including motion practice, discovery, and depositions of key witnesses, the parties engaged in mediation. On May 30, 2023, they participated in a full-day confidential mediation before Layn Phillips of Phillips ADR. Although an agreement was not immediately reached, settlement discussions continued, resulting in a Term Sheet executed on June 11, 2023.
The settlement provided for a $290 million payment by JPMorgan Chase Bank to the class of Epstein's victims. This represented one of the largest settlements ever obtained on behalf of sex trafficking victims against a financial institution. The settlement was preliminarily approved by the court and became final after a fairness hearing and resolution of objections.
U.S. Virgin Islands Action
The government of the U.S. Virgin Islands filed a separate action against JPMorgan Chase Bank, styled Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., 22-cv-10904. The shareholder derivative complaint notes that this action sought "significant monetary damages, including punitive and treble damages" based on JPMorgan's role in facilitating Epstein's trafficking operations, which were centered on his private island Little St. James in the U.S. Virgin Islands.
According to the court's January 2024 opinion dismissing the derivative action, JPMorgan "recently entered into two court-approved settlements concerning this activity—one with a class of Epstein victims and another with the Government of the United States Virgin Islands—in which JPMorgan has agreed to pay a total of $365 million." This indicates the Virgin Islands settlement was for approximately $75 million.
Shareholder Derivative Litigation
In May 2023, the Operating Engineers Construction Industry and Miscellaneous Pension Fund filed a shareholder derivative action against JPMorgan's directors and officers, including CEO Jamie Dimon, former CEO of the Investment Bank Jes Staley, and multiple board members. The complaint alleged breach of fiduciary duty and unjust enrichment based on the directors' and officers' failure to properly oversee the bank's relationship with Epstein and protect the company from the resulting monetary and reputational harm.
The amended complaint, filed in June 2023, included additional allegations about connections between Epstein and certain JPMorgan board members dating back to the Bank One era and Ohio business circles, particularly involving director James S. Crown and former director John W. Kessler.
On August 9, 2023, the court granted defendants' motion to dismiss the shareholder derivative action. In a detailed opinion issued in January 2024, Judge Jed S. Rakoff found that plaintiffs had failed to adequately allege that a demand on JPMorgan's board would have been futile, as required under Delaware law for derivative actions. The court specifically rejected plaintiffs' theory that post-Epstein board members should have discovered and reported Epstein-related SAR violations during compliance reviews mandated by the 2014 Deferred Prosecution Agreement related to the Madoff matter.
Connections to Other Financial Entities#
Beyond JPMorgan, Epstein maintained banking relationships with other major financial institutions. Deutsche Bank became Epstein's primary bank after JPMorgan terminated the relationship in 2013. Deutsche Bank also faced litigation from Epstein's victims and settled for a reported $75 million.
Epstein's financial structure included entities in the U.S. Virgin Islands, including Southern Trust Company and Financial Trust Company, which held substantial assets and were involved in various transactions. Documents in the archive show these entities held millions of dollars in cash and investments as of various valuation dates in 2011-2013.
Evidence of Complicity#
The documentary record demonstrates that JPMorgan's continued banking relationship with Epstein was not a failure of information flow or oversight, but rather a conscious decision to maintain a lucrative relationship despite full knowledge of his criminal conduct and mounting internal opposition.
Key evidence of institutional knowledge includes:
- 2006-2008: Awareness of Epstein's arrest and guilty plea for sex offenses involving a minor
- 2008: Formal "high-risk" designation and documentation that senior management was "uncomfortable with Epstein"
- 2010: Risk personnel questioning whether the bank should maintain a relationship with "a registered sex offender"
- 2011: Explicit identification of payments suspected to be for "services as a procurer"
- 2011: General Counsel's unequivocal statement that Epstein "should not be a client"
- 2008-2013: Exchange of 1,200 emails between Staley and Epstein, some containing concerning content
- 1998-2013: Massive, frequent cash withdrawals that should have triggered SARs but did not
- 1998-2019: Complete failure to file SARs even after terminating the banking relationship
The shareholder derivative complaint frames the issue starkly: "Although JP Morgan is now attempting to lay all blame for its institutional failures on Staley alone in an attempt to escape legal and reputational harm, it is clear that Staley could not have sustained and concealed a 15+ year banking relationship involving tens of millions of dollars without the knowledge and assistance of others within JP Morgan."
Regulatory and Criminal Law Implications#
JPMorgan's conduct in relation to Epstein potentially violated multiple federal statutes and regulations:
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Bank Secrecy Act (BSA): 31 U.S.C. § 5311 et seq. requires financial institutions to assist government agencies in detecting and preventing money laundering by maintaining effective anti-money laundering programs and filing SARs.
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Suspicious Activity Reporting: 31 C.F.R. § 1020.320 requires banks to file SARs for transactions that the bank knows, suspects, or has reason to suspect involve funds from illegal activities, are designed to evade BSA requirements, lack a lawful purpose, or involve use of the bank to facilitate criminal activity.
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Trafficking Victims Protection Act (TVPA): 18 U.S.C. § 1595 provides a civil remedy allowing trafficking victims to sue those who knowingly benefit from participation in a venture engaged in sex trafficking. This was a key legal theory in the Jane Doe class action.
The shareholder complaint notes that JPMorgan had already pleaded guilty to two felony counts in 2014 relating to failures to comply with AML rules, making the bank a repeat offender in this area. The continued failure to file Epstein-related SARs occurred even after this criminal conviction and during the period when the bank was under a Deferred Prosecution Agreement requiring enhanced compliance.
Reputational Impact#
The revelations about JPMorgan's relationship with Epstein caused substantial reputational harm to the bank. The litigation publicly disclosed embarrassing details about senior executives' personal relationships with a convicted sex offender, internal warnings that were ignored, and systematic compliance failures that enabled ongoing sex trafficking.
The court's January 2024 opinion acknowledged that "JPMorgan has suffered and will continue to suffer substantial monetary and reputational harm for its longstanding role in assisting the most egregious sex trafficker in modern history." Beyond the $365 million in settlements, the bank faced negative media coverage, scrutiny from regulators and lawmakers, and questions about its corporate governance and ethical standards.
The case also damaged the reputation of former executive Jes Staley, who left JPMorgan in 2013 to become CEO of Barclays. Staley resigned from Barclays in 2021 amid regulatory investigations into his characterization of his relationship with Epstein. JPMorgan subsequently filed its own lawsuit against Staley, seeking to hold him personally liable for the bank's Epstein-related losses.