Expert report of an attorney on JPMorgan injunctive relief, June 2023

EXHIBIT C¶

EXPERT REPORT OF BRIDGETTE CARR¶

June 16, 2023¶

K. JPMorgan Should Implement Meaningful Injunctive Relief To Prevent Future Participation In Sex Trafficking Ventures¶

• 229. The role of JPMorgan in this case is not unique. Banks are frequently used by traffickers as tools to aid in their trafficking or to exploit their victims. In my experience and according to the National Survivor Study, financial abuse is often part of human trafficking. “Financial abuse by exploiters was reported by a majority of respondents.”3” This abuse may include, like in this case, opening bank accounts or applying for credit cards. It may also include taking out loans, applying for government assistance, and misuse of personal identification for financial purposes.387
• 230. As the National Survivor Study highlights, this type of exploitation by traffickers and aided by financial institutions makes victims extremely vulnerable, even after their trafficking ends, because it limits or even prevents their ability to access basic financial tools.388 Trafficking victims, even after their exploitation, are twice as likely to be unbanked in comparison with the U.S. population.3” This is consistent with my

{sup}386 In Harm’s Way: How Systems Fail Human Trafficking Survivors, Survey Results from the First National Survivor Study, Polaris Project (Jan. 2023), https://polarisproject.org/wpcontent/uploads/2023/06/In-Hanns-Way-How-Systems-Fail-Human-Trafficking-Survivors-by-Polaris.pdf, at 37.¶

{sup}387 /d.¶

{sup}3g8 Id.¶

{sup}389 Id. at 38.¶

experiences in re resenting and advocating for trafficking victims and with experience. After was exited by JPMorgan, she struggled to access basic banking services. I believe, to prevent recurrence of the failures I observed, JPMorgan should work with human trafficking experts and individuals who have been victims of trafficking to develop special accommodations or banking products and protocols to address the unique needs trafficking victims face after being exploited and financially abused. This may, as the National Survivor Study suggests, include “providing access to bank accounts without overdraft fees and penalties.”39°¶

• 231. To further prevent recurrence of the failures I observed, JPMorgan should review its private banking relationship with Epstein and identify missed opportunities to prevent human trafficking, and implement changes that could prevent such missed opportunities from occurring in the future. This review should include participation by individuals who have been victims of trafficking (lived experience experts) and non-law enforcement human trafficking experts. Only a small percentage of human trafficking cases are prosecuted in the United States. Relying solely on the perspective of law enforcement to understand human trafficking may result in too narrow of a focus.
• 232. I also believe that JPMorgan should prevent the opening of accounts in the private bank without independent confirmation of basic identifying details from the customer. JPMorgan should also not rely solely on a potential trafficking sponsor in opening new accounts.
• 233. In my opinion, to prevent recurrence of the failures I observed, JPMorgan should collaborate with human trafficking experts, including at least one that is not from law enforcement and those with lived experience, to develop human trafficking training based specifically on the unique risks of human trafficking inherent in the private banking relationship and to commit to sharing this training within JPMorgan.
• 234. In addition, I recommend that JPMorgan prohibit the participation of any employee who has a personal relationship with a private banking client in the decision to retain or exit that client.
• 235. Finally, I believe JPMorgan should also provide an opportunity for any of Epstein’s victims to present information, in whatever form the victims choose to provide it, about the harm they experienced and the ways in which the bank could have intervened to identify or address their abuse. If the victims agree, JPMorgan should share that information with bankers and compliance personnel throughout JPMorgan. Further, I believe IPMorgan should compensate the victims for their time at the same rate as other human trafficking experts.

{sup}39° Id. at 39.¶