FinCEN suspicious activity report on Jeffrey Epstein, July 2019

No Law Enforcement Information Available¶

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The enclosed information was collected and disseminated under provisions of the Bank Secrecy Act (the BSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311, et seq.; 31 CFR Chapter X. The information is sensitive in nature and is to be treated accordingly. The information may be used only for a purpose consistent with a criminal, tax, or regulatory investigation or proceeding, or in the conduct of intelligence or counterintelligence activities, including analysis, to protect against international terrorism. See 31 U.S.C. 5311. The information cannot be further released, disseminated, disclosed, or transmitted without prior approval of the Director of Financial Crimes Enforcement Network or his authorized delegate. Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of possible criminal activity, akin to confidential informant tips. Unauthorized release of information collected under the BSA may result in criminal or civil sanctions.¶

EFTA00151549¶

FinCEN¶

Financial Crimes Enforcement Network United States Department of the Treasury¶

BSAR Transcript¶

BSA: 31000150416250 and DCN:¶

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The enclosed information was collected and disseminated under provisions of the Bank Secrecy Act (the BSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311, et seq.; 31 CFR Chapter X. The information is sensitive in nature and is to be treated accordingly. The information may be used only for a purpose consistent with a criminal, tax, or regulatory investigation or proceeding, or in the conduct of intelligence or counterintelligence activities, including analysis, to protect against international terrorism. See 31 U.S.C. 5311. The information cannot be further released, disseminated, disclosed, or transmitted without prior approval of the Director of Financial Crimes Enforcement Network or his authorized delegate. Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of possible criminal activity, akin to confidential informant tips. Unauthorized release of information collected under the BSA may result in criminal or civil sanctions.¶

EFTA00151550¶

FinCEN¶

Financial Crimes Enforcement Network United States Department of the Treasury¶

BSAR Transcript¶

BSA: 31000150416250 and DCN:¶

Narrative¶

Schwab’s investigation encompassed the time period ranging from 04/11/2019 to 07/10/2019. The activity in question occurred between 06/28/2019 and 07/10/2019, as referenced in Part II, line 30 of this SAR. The dollar amount $27,658,324.00, referenced in Part II, line 29 of this SAR represents the total amount of outgoing wires of concern which were identified during the investigation period.¶

Jeffrey Epstein was arrested and federally charged on 07/08/2019 with one count of sex trafficking of minors, and one count of conspiracy to engage in sex trafficking of minors; allegations indicate that the activity took place between 2002 and 2005, possibly with an exchange of funds for acts. Jeffrey Epstein is being held in jail, with a scheduled bail hearing on 07/15/2019. Prosecutors consider Jeffrey Epstein a very high flight risk given his enormous wealth, international ties, and private planes.¶

With the recent federal charges and concerns of flight risk, Schwab identified concerns with outgoing wires identified within the account of concern around the time Jeffrey Epstein was arrested and charged.¶

On 06/26/2019, Schwab received a request to send an international foreign currency wire, the request signed by both and Jeffrey Epstein, from brokerage account The wire was requested for 11,150,000 Euros (EUR) or $12,708,324.00 (USD). The wire was remitted to Marc Leon located at Imm El Pacha¶

in Morocco. The funds were sent to an account at Bank Julius Baer and Co. Ltd. located in Zurich Switzerland, account number.¶

Research regarding Marc Leon identified that he is a partner at Kensington Morocco; the firm offers luxury properties in Morocco and France (www.kensingtonmorocco.com).¶

The following day, 06/27/2019, Schwab received a call from ___, asking if it was possible to terminate the¶

aforementioned wire. The Schwab representative asked the reason for the reversal request, and explained the¶

reason was “for a concentrated real estate transaction, and uh, what uh, terms we were told we had on uh an agreement, were uh,¶

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The enclosed information was collected and disseminated under provisions of the Bank Secrecy Act (the BSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311, et seq.; 31 CFR Chapter X. The information is sensitive in nature and is to be treated accordingly. The information may be used only for a purpose consistent with a criminal, tax, or regulatory investigation or proceeding, or in the conduct of intelligence or counterintelligence activities, including analysis, to protect against international terrorism. See 31 U.S.C. 5311. The information cannot be further released, disseminated, disclosed, or transmitted without prior approval of the Director of Financial Crimes Enforcement Network or his authorized delegate. Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of possible criminal activity, akin to confidential informant tips. Unauthorized release of information collected under the BSA may result in criminal or civil sanctions.¶

EFTA00151551¶

FinCEN¶

Financial Crimes Enforcement Network United States Department of the Treasury¶

BSAR Transcript¶

BSA: 31000150416250 and DCN:¶

Narrative¶

not, were reneged on this morning. So uh, we are hoping it still can be a deal, but at this point the terms that I accepted are not agreeable, I want to retract the wire.Ӧ

The wire had been posted, and currency was exchanged. In order to reverse the wire, Schwab relayed to Mr. Kahn that it would be a “best effort” since the 30 minute window to cancel had lapsed. In the event Schwab was successful in reversing the wire,¶

agreed to assume any losses, but alluded that if there was a gain, he hoped he would receive the profit.¶

Schwab was able to successfully retract the wire posted on 06/26/2019, and realized a ($113,527.80) loss after the currency conversion. The funds have been deposited back into brokerage account registered as Southern Trust Company, Inc., on 07/10/2019. indicated the wire for 11,150,000 Euro was sent prematurely, but that he may need to send another wire for even more to a different escrow account. This information was relayed during the conversations regarding the reversal request.¶

On 07/04/2019, Schwab received a second international wire request, again signed by both and Jeffrey Epstein; the request was to send $14,950,000 USD to Marc Leon located at Imm El Dacha in Morocco. The funds were sent to an account at Bank Julius Baer and Co. LTD located in Zurich Switzerland, reflecting an updated account number. At the time of this request, the account did not have a balance to support the wire request as the retracted wire was still pending deposit back to account.¶

sent an email to Schwab five days later on 07/09/2019, asking to “please cancel this wire.” Once the retracted wire was posted to account on 07/10/2019, Schwab made an outbound call to where he confirmed he did not want the $14,950,000.00 wire to be processed. In addition, asked the Schwab representative if future wire requests would require two signatures (note at this time Jeffrey Epstein was in jail). He indicated he would need to send more wires out soon.¶

Please see the attached CSV for detailed information pertaining to the outgoing wires.¶

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The enclosed information was collected and disseminated under provisions of the Bank Secrecy Act (the BSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311, et seq.; 31 CFR Chapter X. The information is sensitive in nature and is to be treated accordingly. The information may be used only for a purpose consistent with a criminal, tax, or regulatory investigation or proceeding, or in the conduct of intelligence or counterintelligence activities, including analysis, to protect against international terrorism. See 31 U.S.C. 5311. The information cannot be further released, disseminated, disclosed, or transmitted without prior approval of the Director of Financial Crimes Enforcement Network or his authorized delegate. Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of possible criminal activity, akin to confidential informant tips. Unauthorized release of information collected under the BSA may result in criminal or civil sanctions.¶

EFTA00151552¶

FinCEN¶

Financial Crimes Enforcement Network United States Department of the Treasury¶

BSAR Transcript¶

BSA: 31000150416250 and DCN:¶

Narrative¶

Schwab maintains all supporting documentation. Written requests for supporting documentation may be sent to Please refer to internal number CA111517 when requesting more information regarding this report.¶

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The enclosed information was collected and disseminated under provisions of the Bank Secrecy Act (the BSA) and U.S. Department of the Treasury regulations implementing the BSA. See 31 U.S.C. 5311, et seq.; 31 CFR Chapter X. The information is sensitive in nature and is to be treated accordingly. The information may be used only for a purpose consistent with a criminal, tax, or regulatory investigation or proceeding, or in the conduct of intelligence or counterintelligence activities, including analysis, to protect against international terrorism. See 31 U.S.C. 5311. The information cannot be further released, disseminated, disclosed, or transmitted without prior approval of the Director of Financial Crimes Enforcement Network or his authorized delegate. Suspicious activity reports filed under the BSA must be treated with particular care given that they contain unsubstantiated allegations of possible criminal activity, akin to confidential informant tips. Unauthorized release of information collected under the BSA may result in criminal or civil sanctions.¶

EFTA00151553¶