EFTA00162425

Subject: [EXTERNAL EMAIL] - Re: Urgent: FinCEN matter

Bank Secrecy Act Confidential



Thank you again for all you are doing to support us on this high-profile matter.

We have one potential correction from list we already sent you. I think you have the name which should be

Realizing that this is a LOT of work, our bosses have inquired whether you have a sense of an ETA, as well as whether we can do anything to support you. Happy to discuss if that is easier for you.



Subject: [EXTERNAL]RE: Urgent: FinCEN matter

Thank you! We are working on your request.

Sent: Monday, March 27, 2023 2:07 PM

Subject: [EXTERNAL EMAIL] - RE: Urgent: FinCEN matter

Privileged/BSA Confidential

EFTA00162426





Sorry that took a minute. Here are our responses. Hope this is what you need. If not, or if you need more information, please just let us know.

## Purpose of disclosing the reports

Discovery in a series of civil lawsuits in the Federal District Court for the Southern District of New York against banks based on the banks’ provision of financial services to sex offender Jeffrey Epstein. Specifically, an unnamed Epstein victim (and a claimed class of victims, “Doe”) are suing both JP Morgan Chase and Deutsche Bank. The government of the U.S. Virgin Islands is separately suing JP Morgan. The cases have been consolidated for discovery.

## Who is requesting disclosing these reports

Both the USVI and JP Morgan are seeking disclosure of the SARs in that matter, and all parties are seeking disclosure in the Doe matters.

## Who will be receiving or viewing these reports

Initially, just the attorneys representing the banks and the attorneys for the plaintiffs. But we anticipate the banks are likely seek further authorization to disclose the reports to the plaintiffs themselves, each other (i.e., for Deutsche Bank to see the JPMorgan reports and vice versa), and witnesses (e.g., expert witnesses, bank employees). There are protective orders in place that cover SAR confidentiality.

## Any other relevant information would assist the agents in deciding whether to object or not

Many of these reports relate to transactions that took place over a decade ago, though some of the reports themselves were not filed until roughly a decade later, after Epstein’s arrest. We are not aware ourselves of any ongoing investigations related to these matters. Although FinCEN normally does not authorize the disclosure of reports in civil litigation, this litigation presents special circumstances, and the presiding judge has indicated he may order the reports’ disclosure if FinCEN does not authorize it.

Best,