JPMorgan Chase

JPMorgan Chase & Co. is the largest bank in the United States by assets, headquartered in New York City and led since 2006 by chief executive Jamie Dimon. From 1998 to 2013 it maintained Jeffrey Epstein as a private-banking and wealth-management client across the period during which Epstein was arrested, pleaded guilty to a Florida prostitution charge, and registered as a sex offender. In 2023 the bank settled two lawsuits in the United States District Court for the Southern District of New York before Jed Rakoff, paying 290 million dollars to a class of Epstein's victims and 75 million dollars to the Government of the United States Virgin Islands, and it filed a third-party claim seeking to shift liability to its former executive Jes Staley. Between 2002 and 2016 the bank filed seven suspicious activity reports on Epstein's accounts totaling about 4.3 million dollars; in August and September 2019, after his arrest, it filed reports covering more than 5,000 wire transfers worth about 1.28 billion dollars.¹²³⁴

The Epstein Banking Relationship

Epstein became a client of JPMorgan's private bank in 1998, and the relationship was managed by Staley, who headed the private bank from 1999 to 2001, led JPMorgan Asset Management from 2001 to 2009 and later the investment bank. The Upper Tribunal found that Staley was introduced to Epstein as a private-bank client in 1999 or 2000.¹⁵ A forensic accountant retained by the Virgin Islands identified 134 JPMorgan accounts owned by Epstein or related people and entities, some opened as late as April 2013: six in Epstein's name, 59 for companies, LLCs and trusts he owned or controlled, and 69 for associates including Ghislaine Maxwell, Richard Kahn, Darren Indyke, Harry Beller and Nadia Marcinkova.⁴⁶

A May 2003 due-diligence report stated that "Jeffrey Epstein, through the trading of his accounts and that of Leslie Wexner, generates one of the largest annual revenue flows of private clients in the private bank." In 2003 Epstein brought in more than 8.1 million dollars in revenue, the most of any investor client of JPMorgan Wealth Management and nearly double the second-highest. The Closely Held Business Group's September 2009 "Wall of Cash" list put his balances at 142,867,562 dollars, more than 15 percent of the book of his banker Mary Casey. A February 2011 team meeting listed him among "Potential Clients to Target Going Forward"; in May 2012 he ranked eighth among the team's top twenty clients by revenue, and a June 2013 report ranked him second. JPMorgan earned more than 8.1 million dollars from Epstein and related entities from 2009 to 2014, the only years for which it produced figures.⁶⁷ Epstein also referred clients to the bank, including Thomas Pritzker, and arranged introductions for Staley to Ehud Barak, Peter Mandelson and Bill Gates; in January 2008 Staley had his assistant arrange a meeting with Barak for JPMorgan executives through Jamie Dimon's office.⁷ The bank retained Epstein through his 2006 arrest in Palm Beach, Florida, his 2008 guilty plea to soliciting a minor for prostitution, and his registration as a sex offender, generating fees and using Epstein as a referral source for wealthy prospective clients.¹ Mary Erdoes, who ran the private bank from 2005 and the asset and wealth management division from 2009, was identified in victims' filings as a defender of keeping Epstein as a client. JPMorgan admitted in the Virgin Islands case that Erdoes, Catherine Keating and Casey knew in 2006 of Epstein's arrest for solicitation of prostitution and that Erdoes was involved in decisions to keep him as a customer.⁷⁸

After the 2006 arrest the bank's Rapid Response Team met on October 17, 2006 and, "after internal discussion with Jes Staley, Mary Erdoes, Catherine Keating, John Duffy and Mary Casey," decided to "keep Mr. Epstein solely as a banking client and on a 'reactive', client service basis," not proactively soliciting new investment business from him. His balances rose from about 32 million dollars in October 2006 to about 121.5 million dollars by July 2008 and 156 million dollars in September 2008. An August 28, 2008 email from Casey counted his assets as a probable outflow "as I can't imagine it will stay (pending Dimon review)." A 2009 due-diligence report recorded that after his conviction "Jes Staley conferred with Stephen Cutler and the decision was made to keep Mr. Epstein as a PB client," for "banking and custody only," with brokerage execution withdrawn.⁴⁷ In 2005 the bank had approved a one million dollar standby letter of credit in Epstein's name backing a Mellon United National Bank loan to MC2 Model Management, the agency of Jean-Luc Brunel, and renewed it on annual review; a 2011 report by the bank's Global Corporate Security division said it was "unknown if the money was given as a secret investment or payment for services as a procurer."⁴⁷

The chronological log of the Operation Leap Year investigation kept by the U.S. Attorney's Office for the Southern District of Florida records a grand jury subpoena to Chase returnable August 18, 2006, issued alongside subpoenas to Colonial Bank, Washington Mutual and Capital One and to Epstein's aviation companies Hyperion Air, Inc. and JEGE, Inc.; a subpoena to "JP Morgan Chase" returnable March 6, 2007; and a subpoena to Chase Bank USA, N.A. returnable April 24, 2007. The same log lists subpoenas to Financial Trust Company, Inc., returnable June 12, 2007, and to Bear Stearns, returnable September 4, 2007, and an April 2007 email between Assistant U.S. Attorney Ann Marie Villafana and the Justice Department's money-laundering specialist Stefan Cassella "re money laundering question."⁹ On September 21, 2012 Epstein's bookkeeper Harry Beller faxed JPMorgan a memorandum directing it to wire 5,000 dollars from Epstein's account, for further credit to the St. Thomas law firm Kellerhals Ferguson LLP, referenced to the Southern Trust Company application fee; Epstein's September 2012 JPMorgan statement records the debit as "Southern Trust Company Application Fee." Southern Trust Company applied for its Virgin Islands tax benefits the following month.¹⁰

In December 2010 anti-money-laundering official Philip DeLuca wrote to the bank's AML director William Langford about "that scum Epstein," and Langford replied, "Let me know if McCleerey waffles on Epstein. No patience for this." In January 2011 Langford asked the private bank to re-evaluate its sponsorship of Epstein and "request re-approval from Steve Cutler if we wanted to retain"; the banker Paul Morris answered, "I thought we decided this was not necessary." A 2011 email recorded that AML operations had asked at a private-bank risk meeting "that we exit this relationship," that no one on a later call favored keeping him, "Seems it is all due to Jes's personal relationship," and that he had "about 212 mil in the bank." In August 2010 Alan "Ace" Greenberg, the former Bear Stearns chairman who had mentored Epstein there, asked Cutler for an exception to the bank's felon policy to keep doing business with him.⁴⁷

On July 19, 2011 JPMorgan, which had bought Bear Stearns in March 2008, proposed settling Epstein's claims against Bear Stearns for 21 million dollars. General counsel Stephen Cutler responded the next day that Epstein was "not an honorable person in any way" and "should not be a client," and on July 21 wrote to Erdoes, "I would like to put it and HIM behind us." An August 4, 2011 Rapid Response meeting concluded that John Duffy would "reach out to Jes Staley and advise that we exit while things are a bit settled." Cutler later testified under oath that Staley and Erdoes made the decision to retain him.⁷⁸ The Upper Tribunal recorded internal evidence that Cutler's view was that Epstein "would have been exited as a client of JPM had not Mr Staley vouched for him."⁵ In March 2012 Duffy, chief executive of the U.S. private bank, told a risk manager he had asked Epstein to withdraw cash for jet fuel from his aviation account rather than his personal accounts, writing, "this is a better pattern than I thought."⁴ Plaintiffs alleged that the bank processed payments consistent with the trafficking operation, including cash withdrawals and transfers to women and to alleged co-conspirators, and that JPMorgan underreported suspicious activity to authorities.⁸ A deposition indicated that Dimon said he was not aware of a 2011 internal warning about Epstein.¹¹

On July 27, 2011 Epstein wrote to Staley and Erdoes, copying Boris Nikolic, chief science and technology adviser to Bill Gates, about a charitable fund: "the mimimum donation would be 100 million. a portfolio will be established for each donor.according to their own critieria, there will be established silos for Medicine, Science , Women issues, Education, etc. ... the charitable fees. audit fees, investment mgmt fees, trustee fees, will all be JPM."¹² On August 27, 2011 he wrote to the same two executives that senior staff of the Gates foundation "say they are getting confusing messages from JPM. They say that JPM wants to use the current foundation to do other things. Bill is at his country house. and most likely will not deal with it before wed."¹³

JPMorgan exited the Epstein relationship in 2013, the same year Staley left the bank for BlueMountain Capital.⁸ On July 18, 2013 compliance staff found another 800,000 dollars in unreported cash withdrawals from 2009 to 2013; one wrote, "issue is he really never stopped the large cash withdrawals," and DeLuca replied, "Shouldn't the business have been telling us this?" The next day Duffy sent Erdoes talking points for the exit conversation, citing "the repetitive nature of your cash transactions" and "your personal history," and she replied, "I think that is fine."⁷ Epstein then moved his accounts to Deutsche Bank, which banked him from 2013 until 2018, brought there by Morris, who had joined Deutsche Bank in November 2012.⁴¹⁴

On August 14, 2013, Duffy wrote to Erdoes that Epstein "maintains he will become Leon's primary advisor and will be calling the shots," referring to Leon Black, and that he had "told [Epstein] that we would work with him as long as it was through the client accounts, JE Entities would not be acceptable. That's ok right?" Erdoes replied, "Y." Banker Justin Nelson later sought meetings with Epstein about "Leon B's family office," wrote to him in May 2015 about "a line of credit for Leon at JPM," and met him at his townhouse at least six times between 2014 and 2018; on August 13, 2014 Epstein wrote to banker Paul Barrett, "are we set now for Leon, $10 million was wired yesterday."⁴

Highbridge Capital

JPMorgan's 2004 purchase of a majority stake in the hedge fund Highbridge Capital Management, founded by Glenn Dubin and Henry Swieca, was described by Staley to the Upper Tribunal as the largest acquisition of a hedge fund to that time, in which Epstein had been instrumental while acting as an adviser to another party.⁵ A March 18, 2004 memorandum to Dimon, then still chairman of Bank One Corporation, chairman William B. Harrison Jr. and David Coulter stated that "Highbridge has approached JB, JPMC based on an existing relationship with the founders/owners, and with Jeffrey Epstein [a founding investor in Highbridge]." A June 16, 2004 email to Staley said, "We continue to be concerned about the role Jeffrey Epstein is or is not playing. One concern that we have is that Jeffrey has been educating Glenn & Henry about our structure and valuation thoughts."⁷¹⁵ Dimon testified that he had "ultimate approval of the transaction," did not know of Epstein's role, and could not explain why Staley wrote to him about it: "You got me."¹⁵ JPMorgan raised its stake to 77.5 percent in 2009. Senator Ron Wyden asked the bank in 2025 about "the reported $15 million paid by JPMC to Epstein related to the acquisition of Highbridge"; the bank did not answer.⁶¹⁶

Suspicious Activity Reports

Seven suspicious activity reports on Epstein filed by JPMorgan between April 2002 and September 2016 covered about 4.3 million dollars. The bank filed no report between April 15, 2003 and August 15, 2008, a span in which Epstein withdrew more than 3.5 million dollars in cash, and none between August 2008 and August 8, 2013; the 2013 report covered activity back to January 2009, and a report filed in March 2015 covered activity from 2006 and 2007. On August 13, 2019, five weeks after his July 6, 2019 arrest, the bank filed a report on 469 wires totaling about 201 million dollars, including payments to women in Russia, Belarus and Turkmenistan through correspondent accounts at Russian banks, among them Sberbank and Alfa-Bank, and on September 26, 2019 a report on 4,725 wires totaling 1,081,819,653 dollars from October 2003 to July 2019. The reports described counterparties who had "been in a relationship with Epstein" or were "procurers of women as part of trafficking," and activity "consistent with negative media involving alleged sex trafficking of minors, the use of multiple accounts, the misappropriation of funds as a money manager and the high-risk jurisdiction of the Russian federation."⁴

The Virgin Islands' forensic accountant found that Epstein withdrew more than 7 million dollars in cash from JPMorgan accounts from 2002 to 2013 and paid more than 3 million dollars to dozens of women. A former JPMorgan executive testified at Maxwell's 2021 trial that Epstein paid Maxwell at least 31 million dollars, about 25 million from JPMorgan accounts; on June 15, 2007 Maxwell received a 7.4 million dollar wire from Epstein, moved it the same day to her company Air Ghislaine's JPMorgan account, and paid 7,352,825 dollars to Sikorsky Aircraft three days later toward an S-76C helicopter registered N908GM.⁴⁶ In March 2026 Wyden told the Senate that "there could be more than $1.5 billion in suspicious Epstein transactions" in the Treasury records his staff had reviewed, and that JPMorgan "waited until after he died to flag more than 99 percent of his suspicious payments."¹⁷

The 2023 Litigation Before Judge Rakoff

Two suits proceeded against JPMorgan in the Southern District of New York before Judge Rakoff. One was brought by a survivor identified as Jane Doe 1 on behalf of a class of women abused by Epstein, alleging the bank knowingly benefited from and facilitated his sex trafficking.² The other was brought by the Government of the United States Virgin Islands, where Epstein owned Little Saint James, alleging the bank ignored red flags about his conduct on the island.³ Both suits asserted that JPMorgan kept Epstein despite documented internal concern and processed transactions that supported the abuse.²³

On March 9, 2023 JPMorgan filed a third-party complaint against Staley within the Virgin Islands action, asserting indemnification, contribution, breach of fiduciary duty, and "faithless servant" claims and seeking to recover compensation paid to him from at least 2006 through 2013.¹⁸ The complaint alleged Staley had concealed his personal activities with Epstein and misrepresented Epstein's character to the bank.¹⁸ Staley moved to dismiss, contending the bank was using him as a "shield" for its own failures.¹⁹

In June 2023 JPMorgan agreed to pay 290 million dollars to resolve the survivors' class claims, and in September 2023 it agreed to pay 75 million dollars to settle the Virgin Islands suit.²³ The bank did not admit wrongdoing in either settlement.³ The Virgin Islands settlement allocated 30 million dollars to charitable organizations, 25 million dollars to strengthen anti-trafficking law enforcement, and 20 million dollars to attorneys' fees.³ Judge Rakoff granted final approval of the 290 million dollar class settlement at a hearing in November 2023.²⁰

Dimon was deposed on May 26, 2023 at the bank's Madison Avenue offices. He testified that he did not recall knowing anything about Epstein until 2018 or 2019, had never met him, and that on retention of clients with criminal records "the ultimate decider would have been the general counsel of the company." Staley admitted in the same litigation that Dimon communicated with him in 2006 about Epstein's arrest. In an April 2023 CNN interview Dimon said, "Hindsight is a fabulous gift," and that the bank had "some of the best lawyers in the world, compliance, out of the DOJ, out of SEC important divisions." Cutler had been the SEC's Director of Enforcement when the Commission's Enron case against JPMorgan was settled for 135 million dollars in July 2003.⁷¹⁵²¹

Project Jeep

On July 22, 2019, the day The New York Times published "Jeffrey Epstein's Deep Ties to Top Wall Street Figures," Peter Neilson, the bank's Global Head of Financial Crimes Compliance, wrote to two chief compliance officers: "Have been working on this (Epstein et al) today. Top of house requested that we expand our analysis to related parties and put together slides. Should have in a few days. We are treating it as a project at this point. There is a highbridge angle and one dating back to Bear." The project was named Project Jeep. On October 27, 2019 a compliance officer circulated a 22-page "summary of the e-comms review that Trade Surveillance conducted regarding Epstein and Staley," with a note that a colleague had built "a timeline combining the e-comms with the relevant transactional activity"; compliance manager Howard Maleton forwarded it the next day under the subject "Project Jeep Current Review."²²²³

The summary grouped the emails by topic. Its headings stated that "Jes Staley appears to have a close relationship with Jeffrey Epstein, regularly communicating with him and seeking advice from him including while Epstein is incarcerated"; that Epstein "appears to maintain relationships with a number of senior business executives and senior government officials globally"; that he "appears to maintain a particularly close relationship with Prince Andrew ... and Lord Peter Mandelson, a senior member of the British Government. He also appears to have a close relationship with Sultan Ahmed Bin Sulayem who is a senior UAE official involved in ownership of the Dubai Ports"; that "Beginning in 2011 Jes Staley and Mary Erdoes have regular communication with Jeffrey Epstein relating to certain strategic initiatives and business proposals"; and that certain messages concerned "lawsuits and litigation involving Epstein, JPMC, Bear Stearns, Highbridge, Zwirn etc." Under the heading on "inappropriate behavior with one reference between Epstein and Staley to a modeling agency," the reviewers paired an August 27 to 29, 2009 exchange, in which Staley wrote that he would be "In London with Jamie, mid week," Epstein asked "Do you need anything there?" and Staley replied "Yep," with a 3,000 dollar wire sent from Epstein's JPMorgan account on August 29, 2009 to a woman in Lithuania associated with a ballet company there, who had received 2,000 dollars from Epstein on January 8, 2009.²²²³ The Government of the United States Virgin Islands told the court that the summary set out "more than four pages of Epstein referrals to JPMorgan," including Andrew Farkas, Nikolic, Gates and Mandelson, and that Dimon had testified, "We did not need introductions to anybody."²²

JPMorgan produced the summary on May 28, 2023, near the close of discovery. The Virgin Islands' counsel, Motley Rice, moved on June 7, 2023 to recall Dimon, depose Maleton and compel production of Bear Stearns records, citing late-produced emails showing that Alan "Ace" Greenberg had gone to general counsel Stephen Cutler "for an exception to the felony policy" for Epstein, a January 19, 2011 message from a JPMorgan Securities employee to Epstein ("Ace would love to speak to Jeffrey") that the bank had not produced as outside the "negotiated scope of search," and a 2008 email stating that "JPM requires top of the house ok for clients who are convicted felons. (ie PCS Legal to Asset Mgt Legal to Cutler to Jaime Daimnon [sic])."²² The bank's counsel, WilmerHale, answered on June 9, 2023 that the summary was compiled after Epstein's death by employees with "no contemporaneous knowledge" of the relationship, that 216 of its 222 underlying emails had been produced months earlier, that Dimon had testified he did not recognize the name "Project Jeep" and had instructed the general counsel to "do everything" to establish the facts, that the author of the 2019 email had confirmed "top of house" meant then general counsel Stacey Friedman, and that a follow-up sent eight minutes after the 2008 email showed "top of the house" there referred to Cutler. It confirmed that after Epstein's 2008 plea "people from legacy Bear Stearns, including Mr. Greenberg," may have approached Cutler about the policy requiring general counsel approval to keep a brokerage account for a felon, a decision "made by Mr. Cutler," and said there was "no evidence that Mr. Greenberg had anything to do with Epstein's accounts at the Private Bank."²⁴ In August 2023, on a separate motion filed July 18, 2023, Judge Rakoff ordered the bank to produce financial records for newly identified women Epstein had paid, and denied the request "to compel production of all documents and information concerning 'Project Jeep' or other investigations by JPMorgan that occurred after Epstein's 2019 arrest."²⁵

The Wyden Inquiry

On September 24, 2025 Wyden sent Dimon 31 questions, citing reported internal emails that described a 2008 retention decision as "pending Dimon review" and Cutler reviewing Epstein documents "for Jamie," and asking why the bank waited six years after exiting Epstein to report his transactions.¹⁶ JPMorgan replied on October 10, 2025 that it had "fired him as a client in 2013," that "with the exception of former JPMC executive Jes Staley, the Firm's executives (current and former) are respected professionals who acted with integrity," that discovery of more than a million pages had not established Dimon's knowledge of Epstein before 2019, and that it was "not legally permitted to comment" on any suspicious-activity filings under the Bank Secrecy Act.²⁶ A second letter on October 20, 2025 drew another reply without answers or documents, and the bank declined to give Wyden's staff the deposition transcript of Morris.⁴

Wyden's August 4, 2026 report concluded that JPMorgan likely violated federal anti-money-laundering law and named Erdoes, Staley, Cutler, Duffy, Nelson, Barrett, Casey, Morris, David Brigstocke and Jeff Matusow among thirteen bankers whose conduct it said merited investigation, noting that several still held senior posts. None has been charged. On June 24, 2026 the board's compensation committee approved a one-time 20 million dollar retention award for Erdoes.⁴²⁷