USVI Complaint Against JPMorgan Chase

COMPLAINT AND DEMAND FOR A JURY TRIAL Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A. S.D.N.Y. No. 1:22-cv-10904 Filed: December 27, 2022 This complaint opened the U.S. Virgin Islands' federal civil action against JPMorgan Chase Bank, N.A. The Government alleged that JPMorgan maintained banking services for Jeffrey Epstein and his related accounts while red flags about trafficking, cash withdrawals, transfers, and Epstein's criminal history accumulated inside and outside the bank. The pleading asserts claims under the Trafficking Victims Protection Act, the Virgin Islands Criminally Influenced and Corrupt Organizations Act, and the Virgin Islands Consumer Fraud and Deceptive Business Practices Act. It also relies on Bank Secrecy Act concepts to frame the bank's alleged knowledge of suspicious financial activity. The Government brought the case as a public enforcement action, describing financial institutions as entities that can either enable or interrupt trafficking networks. The complaint alleges that JPMorgan processed wires and cash transactions connected to Epstein's operation and that the bank benefited from Epstein's assets, introductions, and promised business. It also places former JPMorgan executive James Staley in the factual background, alleging that senior-level relationships helped preserve the bank relationship. These are allegations in an initiating pleading, not judicial findings. For archive purposes, this filing is the anchor record for the USVI/JPMorgan financial-liability litigation. It connects Epstein's accounts, bank compliance duties, and the later discovery and settlement activity that followed in 2023. Source: SDNY / CourtListener RECAP Available at: https://storage.courtlistener.com/recap/gov.uscourts.nysd.591653/gov.uscourts.nysd.591653.1.0.pdf