The Epstein Files:
When a plane crashes, an investigation is undertaken and a root cause is identified and lessons for the wider aviation industry are learned and new adaptations implemented.
Fighting financial crime should do the same, but “crashes” take years to investigate and partisan findings generate limited results which rarely means adequate programme adjustments are made.
The case of Jeffrey Epstein is a case in point. This is an almighty plane crash, where investigations everywhere are being mishandled.
Despite decades of suspicions and reporting of SARs he still maintained bank accounts and the financial intelligence that was identified appeared to have no material impact internally in some of the main banks he had accounts and or with those supervising and or from those receiving the intelligence which goes to the very heart of the system we all want to work better.
With so much information now publicly available it is possible to use the Epstein affair as a unique financial crime case study and to offer lessons learned, which are opinions and not facts, but ones FCN have been careful to come to and do so mostly but not exclusively with the benefit of hindsight.
Nevertheless they raise uncomfortable questions for all system participants.
FCN is not naming Bank’s or people because that’s of no interest to FCN and this is focused on lessons learned and not on criticising others.
FCN is sharing these lessons learned plus 10 Key Takeaway’s, plus FCN’s financial case study summary on Epstein so others can reflect and make up their own opinions.
There is a more detailed 50 page case study which FCN are not publishing but is available to professional financial crime fighters and policy makers who want to contact FCN directly, that are interested in carrying out their own assessment to learn the lessons they feel are important.
After all, once we stop learning, the criminals exploit that and just as important, we stop getting better!
Lessons Learned:
Money was at the heart of supporting Epstein’s human trafficking network, as money was the reason vulnerable children and young girls were persuaded to get involved with him, alongside grooming, manipulation, intimidation and his social circle and the connections that helped project power and influence. A number of young girls were supported, including through financing housing and scholarships. All were used and abused. Others once abused were also persuaded to act as recruiters. The numbers of those abused including minors are substantial with hundreds possible with some suggesting as many as a 1,000, over 30 years. Epstein had many financial relationships, with Banks, Investment Banks and Hedge Funds in the USA, the US Virgin Islands, France and Switzerland.
By the time of his arrest and his apparent suicide in 2019, Epstein left assets of $577 Million. Epstein’s residence and tax agreements with the USVI from 2003 – 2019 saved Epstein an estimated $300 million in taxes, paying just 4% compared to equivalent US corporate taxes at the time of 35%. That indicates Epstein generated almost a $1 billion in income over his professional career, with estimates that just over half came from fees paid by or monies embezzled from clients, not actual trading and the rest from trading and or investment gains. That wealth was accumulated from literally nothing to about $1 million in 1980 and to about $20 million in 1990. After that HSI wealth grew substantially and is detailed in the financial crime case study that supports this exercise.
For the purpose of this exercise through the focus is on 2 Banks that operated many accounts in the USA for Epstein and his companies for many years. As this paper is about lessons learned and not about naming and shaming, they have been named as Bank 1 and Bank 2.
Whilst Epstein may have generated up to and or exceeding $1 billion dollars, based on the evidence revealed in publicly available materials, the amounts used to finance these abusive activities, are likely to be around $6 million in cash and in the $10 millions in wire transfers, representing about 2-3% of his total income over this period, and maybe 5-6% of his estimated net wealth.
Much of these financial transactions were identified as suspicious both before his arrest in 2006 and after his release from prison in 2009 and before his subsequent second arrest in 2019. Financial transactions of concern included large and or repeat large cash withdrawals and repeat payments including large cross border payments which included generic references such as to models, recruiters and intermediaries. His use of numerous and complex offshore companies, could have made it more difficult to identify suspicious transactions, but AML Compliance teams identified many as suspicious and reported these in the form of SAR’s but also relevant CTR’s also.
It appears however that the identification and reporting had little material impact or effect, in terms of actions reasonably expected that could have been taken in response, (adequate explanations, additional controls including restrictions and exits), by Bank’s involved and by the system recipients of SAR’s and CTR’s.
There is no evidence that SAR’s or financial investigations played any part in the 2005 investigation and 2008 conviction of Epstein or his 2019 arrest, which related to and was limited to the period 2002 – 2007 only. There is also no evidence that SAR’s or financial investigations played any part in the arrest in 2021 and conviction of Ghislaine Maxwell in 2022 which related to and was limited to the period 1994 – 1997 only. In contrast however, there is evidence that SAR’s and CTR’s filed related to Epstein and 14 other associates or targets were reviewed and considered by the DEA in connection with their investigation that started in 2010 and ended in 2015 without any charges being brought. The investigation related to whether Epstein was involved in drug trafficking offences and or prostitution between New York, Florida, Paris and the Caribbean (USVI). This investigation and the work including the financial analysis carried out was not shared with or used by those that led the investigation that culminated in Epstein’s arrest in 2019.
Epstein was in large part able to withstand being financially excluded after his arrest in 2006, first by claiming he was not guilty, and then later after he pleaded guilty and was imprisoned, by making the case that the underage sex violation was a mistake and that he was effectively being shaken down by a young prostitute and he had been caught in a trap. This myth was accepted too easily at best or the truth not considered important enough, when considering Epstein’s character and reputation in terms of whether to bank Epstein after this event and or considerations as to character and reputation were considered less important and short term business interests were prioritised over compliance concerns.
The Epstein Files:
10 key Anti Financial Crime Takeaways
- Bank 1 viewed Epstein as a high-value, high-revenue client. Consequently, senior leadership prioritised business profits over Anti-Money Laundering (AML) compliance. Furthermore, a senior leader’s close friendship with Epstein may have compromised the bank’s oversight. Similarly, Bank 2 prioritised business benefits over AML compliance concerns.
- This despite Epstein’s arrest and conviction between 2006-2008. However, the relative limited nature of the charge and conviction and the plea deal under reported the true extent of Epstein’s widespread sexual abuse including of minors. Epstein propagated the idea that the case against him was limited and unfair, and that legal cases brought subsequently against him were from girls who he had thought were not underage and/or they were being manipulated by lawyers to seek significant compensation. Bank 1 and Bank 2 senior business leaders were too easily persuaded by this argument and or by the argument that Epstein had paid for his crimes, or they didn’t treat these crimes in the same way as for example corruption or fraud and so they were far too willing to do business and or continue to do business with him.
- Epstein needed many accounts to be opened and operated (20-40) which meant monitoring for unusual or suspicious activity more difficult, especially with many inter-company transactions and other individuals working for Epstein picking up and dealing with a significant amount of the cash privately.
- Both Bank 1 and Bank 2 AML Compliance, focussed on cash withdrawals, but probably never received acceptable explanations, so repeat suspicions occur, as do repeat filings of SAR’s were necessary. In Bank 1 it was 5 SAR’s and exit, whereas in Bank 2 it was 2 SAR’s and exit.
- Bank 1 appeared not to have any suspicions of fraud or misappropriation of assets, which Les Wexner complained about later but related to Epstein’s role as financial adviser from 1989 – 2007. It is unclear whether Epstein’s relationship with Towers Financial & Steven Hoffenberg was known or appreciated by Bank 1, which might have been relevant to suspicions of fraud in connection with seed funding for Epstein’s wealth in the late 1980’s. It is unclear whether Bank 1 complied with the Wolfsberg Private Banking Principles published in 2000.
- Both Bank 1 and Bank 2 AML Compliance deferred to senior business leaders regarding the decision as to whether to exit the client or not. Whilst it is debatable whether this is solely a final decision for senior management, what isn’t debatable is that following SARs filed and suspicions raised, unless satisfactory explanations are received then controls should be put in place to prevent further recurrence of the concerned activity.
- Both Bank 1 and Bank 2 rated Epstein as high risk, with Bank 1 in 2008 and Bank 2 from the start of the relationship in 2013. Neither Bank’s designation made much of a difference. Both do not appear to have a process of annual reviews of the most sensitive high risk clients being reviewed by a specialist group within AML Compliance and these then being annually reviewed with the Group CEO and Chairman of the Bank. The Group CEO of Bank 1 has publicly claimed he had no knowledge of the recommendations of Compliance and the General Counsel to exit Epstein in 2011 and/or later, when Senior Executive 1 used his influence to ensure the client was retained. Senior Executive 1 has claimed otherwise. In Bank 2, Epstein was considered a PEP, due to his contacts with a former US President and a member of the British Royal Family. This is probably an excessive use of the PEP designation, but at least was overly cautious.
- Bank 2 did not sufficiently consider why Bank 1 was exiting the client. Bank 2 could have sought to use Section 314 b of the Patriot Act and to receive information from Bank 1’s AML Compliance team, regarding details of any concerns they may have had, in particular the information that was the subject of the SARs filed by Bank 1.
- According to reporting the second federal investigation was started in 2019, following Miami Herald articles in 2018 about the lenient 2008 flawed Epstein plea deal. The 2019 case only focusses on abuse between 2002 – 2005, so no investigation appears to have been carried out about Epstein’s abuse after 2007 and SAR’s filed have apparently been helpful or used.
- In both cases, there is no evidence that Bank 1 or Bank 2’s regulators, were aware of these matters, before they came into the public domain. Bank 1 was subject to a regulatory order in 2010 in relation to AML including anti fraud controls and Bank 2 in 2020, relating to the Epstein accounts, after the event. US regulators are also now suggesting Banks should not be exiting customers for reputation risks, which may lead US Bank’s in the future to maintain such relationships which would be a mistake.
Key Dates including Finance Related:
1953 – Epstein was born in Brooklyn, whose early life was in Coney Island, New York City.
1976 – 1981 – Joined Bear Stearns and learned about financial markets.
1980 – Epstein was not wealthy with assets estimated at or below $1 million.
1981 – 1987 – Financial Bounty Hunter and Financial Adviser to wealthy clients.
1985 – 2013 – Epstein banked at Bank 1 and met the Head of the Bank and the Head of the Private Bank in 1999.
1987 – 1989 – Adviser to Tower Financial (largest Ponzi Scheme collapsed in 1994).
1989 – 2007/2008 – Financial Adviser to Billionaire Les Wexner.
1990 – Epstein was wealthy with assets estimated at or around $20 million.
1994 – Epstein and Maxwell abuse 13 year old girl at a fine arts summer camp.
1999 – Epstein met the CEO of Bank 1 and the Head of the Private Bank in 1999.
2000 – Epstein was wealthy with assets estimated at or around $200 million.
2002 – 2005 – 3 SARs filed by Bank 1 in connection with large cash withdrawals
2003 – 2019 – Secured favourable tax agreement with the USVI for his corporate profits.
2005 – Epstein was very wealthy with assets estimated at or around $500 million.
2005 – Palm Beach Police investigate Epstein after a sexual molestation complaint from a parent of 14 yr old girl, introduced to Epstein by an older girl at her school.
2006 – Epstein was arrested in Miami and charged with sexual crimes.
2008 – Agreed to a lenient Federal Non Prosecution Agreement. Epstein pleads guilty to “procuring a child for prostitution and sex trafficking” and is given 18 months imprisonment and officially registered on the sex offenders register. Epstein was to serve 13 months, starting July 1, 2008, with very accommodating conditions.
2008 – Bank 1 filed 4th SAR related to large cash withdrawal for the period 18 January 2007 – 16 June 2008, which included the period between Epstein’s arrest and his imprisonment.
2008 – 2013 – 17 out-of-court civil settlements linked to Epstein’s conviction, including with girls who claim they were underage at the time.
2010 – Epstein’s wealth was hit by his conviction and the financial crash of 2007/2008 but he was still wealthy estimated at or around $300 Million. DEA start an investigation into Epstein and 14 other targets which was closed with no charges being brought in 2015.
2012 -2017 – Agrees to act as financial adviser to Hedge fund billionaire, Leon Black.
2013 – Bank 1 filed its 5th SAR on 8 August 2013 related to suspicious cash withdrawals that were between 2009 – 2013, following which Bank 1 decided to exit the Epstein relationship (8 months after Epstein’s major Bank 1 sponsor had left the Bank).
2013 – 2019 – Epstein opened new bank accounts at Bank 2, where his former Bank 1 Private Banking client adviser was now based since December 2012.
2015 – Epstein’s wealth was estimated at or around $500 Million.
2016 – 2018 – 2 SARs filed by Bank 2 in relation to large cash withdrawals from Epstein’s accounts and in late 2018, Bank 2 decided to exit Epstein accounts.
2018 – The Miami Herald published articles titled “Perversion of Justice”, which caused outrage about Epstein p’s prior actions and the leniency of his sentence and the likelihood of an NPA.
2019 – NY prosecutors look again at Epstein after Miami Herald reports and realise the NPA only applies to cases in Florida. They find other cases between 2002 – 2005 and arrest him in July on Federal Sex Trafficking charges. Epstein committed suicide a month later. He Leaves an estate valued at $577 Million. Wexner claims Epstein stole hundreds of millions of dollars from him.
2020 – Bank 2 agrees to pay $150 million in settlement with US regulators in connection with weaknesses in its AML operation due to its actions regarding its Epstein accounts.
2020 – 2021 – Ghislaine Maxwell is arrested (2020) and convicted (2021) on 5 out of 6 charges including one of sex trafficking of a minor. She was sentenced to 20 years in federal prison.
2023 – Bank 1 settles with the 200 Epstein victims for US$290 million and settles with the U.S. Virgin Islands for US$75 million, publicly acknowledging its “mistake” and regretting banking him, though Bank 1 also stated that, “it did not help him commit crimes”.
2023 – Bank 2 agreed to pay $75 million to Epstein’s victims in a class action settlement. The CEO of Bank 2 that having Epstein as a client was “a critical mistake and should never have happened”.
2025 – Former Head of Bank 1’s Private Bank (and later Head of its Investment Bank) and main Bank 1 supporter of Epstein gets a lifetime ban from UK FCA for failure to be honest re Epstein.
2025 – US Congress passes the Epstein Files Transparency Act requiring the US Government (DOJ) to publish all relevant Epstein related information.
2026 – The DoJ has since released over 3 million pages of documents, 2,000 videos and and 180,000 images. The documents include a draft indictment from 2007 referencing a 200 plus count indictment, 3 unnamed Co defendants who procured over 200 underage girls.
2026 – Former UK Prince Andrew was arrested following allegations of providing Epstein with confidential UK government documents from his time as UK Trade Envoy (2001 – 2011).
2026 – As at end of February, active investigations are ongoing in the UK, France and Norway into matters connected to Epstein, but none in the USA, except for hearings in Congress.
Financial Crime Case Study – Summary:
This Case study summary has been compiled using publicly available information, including news and media reports and articles, and from published Books in particular of victims, court case allegations and defences and testimony. It is also a summary, which by its nature will not include all materials and is highly selective. No doubt some if not a lot of this could be contested and alternative opinions, and evidence provided in order to question and challenge the contents of the information in the public domain. As a result the reader is encouraged to keep a very open mind and to consider this summary in that light. The author does not presuppose this summary to represent anything other than a short condensed summary of some publicly available information.
A separate more detailed Appendix – 51 page summary upon which this case study summary is based is not shared or made public, but is available on request for professional financial crime fighters and others that would benefit from a more detailed summary, provided the caveats referred to above are understood and the summary once shared remains confidential and is not shared with third parties, without the authors prior consent.
This case study summary is 30 pages long and is made up of a summary of information compiled with respect to Epstein’s work and financial activities including those with and by his main bankers during the period from the 1970’s to 2020.
Key dates include:
- June 2006 being his his first arrest on sex related charges which led to his conviction in 2008, where Epstein pleaded guilty to “procuring a child for prostitution and sex trafficking” and is given 18 months imprisonment and officially registered on the sex offenders register. Epstein served 13 months, starting July 1, 2008.
- 6 July, 2019 when he was arrested for the second time, but on more serious sex trafficking charges including the abuse of minors, but only related the period between 2002 – 2005.
- 10 August, 2019, when Epstein committed suicide. He left an estate valued at $577 Million.
Sexual Abuse, Investigations and Prosecutions:
The first reports of sexual abuse by Epstein, in particular the abuse of minors can be identified between 1994 and 1997, when Epstein was in his early 40’s. In 1994, a victim met Epstein and Maxwell at the Interlochen Centre for the Arts, a Michigan fine arts summer camp. A lawsuit has since claimed that the victim, named as Jane Doe, met Epstein and Maxwell at the camp when she was 13. Epstein allegedly bragged to her about being a patron of the arts and giving scholarships to talented young artists. The complaint also alleges that Doe was used as a “guinea pig” for their grooming scheme and subjected to years of escalating sexual abuse. Epstein’s ties to academia and his offers of education created financial dependence that could then be withdrawn, creating a form of dependence and control masked as generosity.
Whilst this and many other cases were not reported to the police, a compliant by a parent in 2005 of a 14 year old daughter being molested at Epstein’s Palm Beach mansion, started a police led investigation. This investigation found evidence of more underage girls who said they too had been abused. Several described being paid hundreds of dollars for massages that escalated into sexual acts. Some said they were encouraged to recruit other girls. Police ultimately identified dozens of potential underage victims (often reported as around 30+ during that phase), with many considered as vulnerable.. By mid 2006, the Palm Beach police chief believed that detectives believed there were probable cause for multiple felony charges, including unlawful sex with minors.
In July 2006, after a grand jury process, Epstein was arrested in Palm Beach, however the grand jury indicted him on a single felony count of solicitation of prostitution and several lesser counts – far fewer charges than police had recommended. He was released on bail shortly afterward.
The case was taken over by federal prosecutors and the FBI. In 2007, Epstein’s lawyers negotiated a Non Prosecution Agreement with the US Attorney’s Office in Florida. This Agreement stopped federal prosecution of sex trafficking charges against Epstein which had been investigated between 2001 through to September 2007, related to Florida cases, and granted immunity to potential co-conspirators and was negotiated without informing the victims, despite federal law (Victim’s Rights Act) requiring prosecutors to keep victims informed of major developments. Potential co-conspirators including long standing people carrying out tasks such as House managers, Personnel Assistants, Pilots and Recruiters. As a condition of the NPA, Epstein was required to plead guilty in Florida on State charges of solicitation of prostitution and procurement of minors for prostitution. The NPA required Epstein to serve 18 months in jail, which started on 1st July, 2018 (he ultimately served 13 months with credit and early release), to register as a sex offender and to pay restitution to victims. Epstein’s prison conditions were extremely beneficial to him. He was housed in a separate wing of the county jail. He was allowed work release for up to 12 hours a day, 6 days a week.
In December 2010, the US Drug Enforcement Agency started an investigation into Epstein and 14 associates or potential Co-conspirators. In a released May 2015 memo written by the Drug Enforcement Agency (Organised Crime Drug Enforcement Task Force “OCDETF”), it confirmed the existence of an investigation (Operation Chain Reaction) into Epstein and 14 potential Co-conspirators which had started on 17 December, 2010. In the memo it is stated that, the “DEA indicates the above individuals [Epstein plus 14 others], are involved in illegitimate wire transfers which are tied to illicit drug and/or prostitution activities occurring in the USVI anda NYC”. The investigation looked into suspicious Cross border wire transfers and Epstein and his associates travel, to and between USVI, Paris France, Miami and NYC. Cash Transaction reports and SARs filed by numerous bank’s were reviewed. The investigation Did not lead to any charges being brought.
In November 2018, the Miami Herald published articles titled “Perversion of Justice”, led by Julie K Brown which called into question the lenient treatment given to Epstein in 2008. The Herald conducted dozens of interviews with Epstein’s alleged victims, and made Freedom of Information Requests to law enforcement agencies and looked through relevant court papers, realising their must have been a plea deal which was sealed (confidential). When they revealed the results of their investigative work, their findings sparked widespread outrage.
Federal prosecutors, including those in the Southern District of New York began reviewing the 2008 NPA (the plea deal) and realised the deal only applied to acts in Florida by Epstein and covered conduct between 2001 – 2007. This allowed them to pursue a legally independent federal case in New York. They had to gather new victim accounts, including cases outside Florida, but did not look for any new evidence beyond 2007. In fact no investigation appears to have been carried out on Epstein’s activities after this date.
In 2019 a New York grand jury delivered a 2 count indictment on July 2, which led to Epstein’s arrest in July 6th, aged 66. The indictment contained 2 felony charges, i) conspiracy to commit sex trafficking of minors, and ii) sex trafficking of minors. The first charge carried a maximum sentence of 5 years in prison whereas the second carried a maximum sentence of 40 years in prison.
The indictment alleged that, “between 2002 through 2005, Epstein sexually exploited and abused dozens of underage girls by enticing them to engage in sex acts with him in exchange for money. Epstein allegedly worked with several employees and associates to ensure that he had a steady supply of minor victims to abuse, and paid of those to recruit other underage girls to engage in similar sex acts for money. He committed these offences in New York and Palm Beach, Florida”.
Epstein pleaded not guilty in his initial appearance in an SDNY federal court. He was denied bail in part because he was considered a flight risk given his wealth, connections and prior conduct. The case was set for trial in 2020. Epstein committed suicide on August 10, 2019.
It is believed, Epstein abused as many as or even more than 1,000 young girls, many underage. Ghislaine Maxwell was arrested in 2020 and was found guilty in 2021 on 5 charges including one of sex trafficking of a minor between 1994 – 1997. She was sentenced to 20 years in federal prison. No one else has been charged or appears to be under investigation for assisting Epstein in his sexual abuse.
Financial Case Study:
From this summary, Epstein started to become wealthy in the 1980’s, before he started work for the billionaire Les Wexler in 1989, worth about $20 million, with suspicions that some of it, could well have been the seed funding for his wealth, coming from the Towers Financial Ponzi Scheme which collapsed in the 1990s and those involved imprisoned, and was described as the largest Ponzi scheme in history at that time. A decade later by 2000 his estimated net worth was likely somewhere around $100 Million, and by 2005 at $500 Million. His arrest and convictions affected his growth in income and he lost money during the financial crises, (2007 – 2008) as well as paying back monies that Wexner believes were stolen on misappropriated from him (2007 -2008). Nevertheless after his release from prison, he was able to resume his financial advisory activities and was supported by important relationships in banking. Whilst Epstein had a number of Banks that had operated accounts at different times, the focus of this executive summary focusses just on 2 Bank’s (Bank 1), that operated accounts until 2013 and (Bank 2), that operated accounts from 2013 – 2019. Even when Bank 1, decided to exit Epstein in August 2013, Bank 2 was willing to accept him. Bank 1 decided to exit after Epstein’s main senior lead sponsor had left and after filing 5 SAR’s, all of which reported excessive cash withdrawals, though the 5th SAR in August 2013 reported amounts of $920,000 for the period 13 January 2009 – 31 July 2013, which indicated Epstein’s behaviour had not changed, despite his earlier conviction and incarceration. Bank 2 agreed to accept Epstein, not least because Epstein’s former private client adviser at Bank 1 transferred to Bank 2 at the end of 2012., but also with full knowledge of Epstein’s conviction in 2008 and subsequent court cases by his victims claiming sexual abuse. Despite exiting Epstein in August 2013, Bank 1 would file 1 more SAR, before Epstein’s arrest in 2019 and then 2 more after that. Bank 2 filed 2 SARs, one in 2016 and one in 2017, related to the volume and nature of cash withdrawals on Epstein’s accounts, and communicated its decision to exit Epstein’s accounts by December 2018, though small account balances remained at the time of Epstein’s arrest in 2019. Whilst billionaire Les Wexner, provided the main source of revenue for Epstein in the 1990’s and up until 2007/2008, it was the hedge fund billionaire Leon Black who provided most of Epstein’s revenues from between 2012 – 2017.
Estimated Net Worth:
By the time of his arrest and his alleged suicide in 2019, Epstein left assets of $577 Million. Epstein’s residence and tax agreements with the USVI from 2003 – 2019 saved Epstein an estimated $300 million in taxes, paying just 4% compared to equivalent US corporate taxes at the time of 35%. That indicates Epstein generated almost a $1 billion in income over his professional career, with estimates that just over half came from fees paid by or monies embezzled from clients, not actual trading and the rest from trading and or investment gains.
Suspicious Activity:
Suspicious transactions reported by both Bank 1 and Bank 2 are estimated as related to approximately $6.6 million from 2001 to 2018, which on average amounts to approximately $370,000 a year, though larger annual amounts were identified between 2002 – 2005. The SAR’s appear to be totally focussed on cash withdrawals and suspicions of sex trafficking and or sexual exploitation but at no time, it is believed were any suspicions of fraud or misappropriation of assets considered. It should be noted and assumed likely that additional third bank SARs were also filed along with many Cash Transaction Reports.
According to a DEA 2015 Memo, (released in March 2026), a review of reported Suspicious Activity Reports (SAR’s) filed between 2010 – 2015 with the subject being either Epstein’s or his associates also under investigation at the time, Epstein is the subject of 7 SARs ( 1 in 2013, 2 in 2014 and 4 in 2015) totalling $5,672, 921. In total 14 (including Epstein) of the 15 targets investigated by the DEA are the subjects or included as included in SARs filed during this period.
Cash Transaction Reporting:
According to a DEA 2015 Memo, (released in March 2026), a review of reported Cash Transaction Reports (CTR’s – cash transactions exceeding $10,000) reveals 39 CTR’s were filed between 2010 – 2015 by most likely Bank’s (12 in 2010, 10 in 2011, 9 in 2012, 6 in 2013, 2 in 2014) amounting to cash withdrawals of $1,362,000 by Epstein or his associates also under investigation at the time. Epstein himself was the subject of 2 CTR’s in 2011 and 6 CTR’s in 2010 totalling $233,397.
A chronological summary of important key dates and activities are further set out below:
1970’s Summary:
In 1970, Epstein was 17 years old, and had just a year earlier graduated from the Lafayette High School, on Coney Island. In 1970, he studied at Cooper Union and NYU but did not graduate, leaving in June 1974. Later that year in September 1974, Epstein aged 21 started working as a mathematics teacher at a prestigious prep school “Dalton School”. At Dalton he allegedly shows inappropriate behaviour towards underage female students, paying them constant attention. In June 1976, Epstein was dismissed from the Dalton School for poor performance. Later that year, Epstein began work at the US Investment Bank, Bear Stearns in New York. Epstein had apparently impressed a Wall Street executive with his knowledge of mathematics at the Dalton School and was then recommended he apply as a hire to Alan Greenberg, who was a Senior Partner at Bear Stearns. Epstein joined Bear Stearns as a low level junior assistant to a floor trader, but advanced to become an options trader and the moved to advising wealthy clients on tax mitigation strategies. In 1980, Epstein became a limited partner at Bear Stearns.
By 1980, Epstein was not a wealthy man, though he had some money, for example just a year later he would lend money (US$20,000) to a friend to buy stock, and when he left Bear Stearns and was paid his full bonus estimated at US$100,000 for 1981, which suggests similar bonus for 1980. At this stage it’s unlikely Epstein was worth much more than the savings from his employment at around or under $1 million.
1980’s Summary:
During the 1980’s, Epstein became a limited partner but then left his job as an exotic options trader working with the Banks wealth management clients at Bear Stearns (1981), without a new job to go to, and following a fine for a regulation breach. He established his own business chasing and recovering defrauded clients monies, and working as an adviser to wealthy people on individual mandates, albeit without much official or transparent arrangement. These included according to reports, the billionaires Elizabeth (Lilibet) Johnson and the French Rothschild family. Epstein became an adviser for 2 years to a company (Towers Financial – 1987 – 1989) and for a person (Steven Hoffenberg) who would a few years later be considered the promoter of the worlds largest Ponzi scheme (as at that date – $400 million) and found guilty of fraud (1994). Epstein was paid US$25,000 per month (equivalent of US$71,000 a month in 2025). In 1988, Hoffenberg gave Epstein a $2 million loan, that Epstein would never have to pay back. In 1988, Epstein claimed to be worth US$20 million, with US$7 million in securities, US$1 million in cash and US$11 million in other assets. In 1989, Epstein left Towers and began working for the billionaire Les Wexner, initially to help with his personal financial affairs, as Wexner was running his business empire and he needed help with managing his assets, financial, property etc. In 1991, Epstein was granted power of attorney over Les Wexner’s personal financial affairs. If Wexner, had accounts at Bank 1, where Epstein also banked, then this would have made him a very important person, for Bank 1, but also someone who was not related, had no regulatory status but had incredible control and access to one of their most important clients funds, where heightened fraud risks should be considered and monitored.
By 1990, his estimated net worth was likely somewhere around $20 – 25 Million, with perhaps half of this in bankable assets. He had opened his account at a bank that was later acquired by Bank 1 in 1985.
1990’s Summary:
Financially, during the 1990’s, Epstein’s main income came from his relationship with and as financial adviser to the billionaire retailer Les Wexner. Whilst his income from his activities with Wexner is not disclosed, Epstein spent a great deal. He spent approximately US$50 million, on purchases of the New Albany House ($3.5 Million), the Manhattan Townhouse ($20 Million), the USVI Island and building property and amenities (est $10 Million), and payments to Ghislaine Maxwell ($18.3 Million). He received sales proceeds from the resale of the New Albany property ($8 Million). It is not clear how much Epstein earned or stole from Les Wexner during this period, or how other investments were performing.
Therefore by 2000 his estimated net worth was likely somewhere around $100 Million, with perhaps bankable assets in the tens of millions of dollars. Whilst he had accounts at Bank 1 he also had accounts at other Banks too.
2000’s Summary – Part 1 2000 – 2005:
During this period, Epstein’s main income still came from his relationship with and as financial adviser to the billionaire retailer Les Wexner. In 2002 Epstein represented, his company FTC had 20 employees and capital of $88 million (USVI a tax agreement application). In 2003, Bank 1 estimate Epstein’s net worth at about $300 million. In 2004, an intermediary fee is paid to Epstein ($15 million) in connection with a Bank’s acquisition of a Hedge Fund for $1.3 billion. Epstein is reported to have generated $127 million in revenues in FTC in 2004, his best year ever, as his firm swelled to $476 million in net assets, according to other financial reports.
Whilst the account and relationship at Bank 1 was considered a great success by the Bank 1’s Senior Executive 1, another picture was emerging. Bank 1’s AML team, had suspicions regarding Epstein’s high volume of cash withdrawals. 3 separate SARs had been filed between April 2002 – April 2003, related to cash transactions amounting to $2.285 Million. Also in 2004, according to reports, Epstein’s cash withdrawals continued — a total of more than $1.7 million in 2004 and 2005. Some of the withdrawals took place at the bank branch in Bank 1’s headquarters, where Epstein’s accountant regularly arrived to cash huge checks written from Epstein’s various accounts. At Epstein’s request, the private bank also agreed to open accounts for two young women without actually speaking to either of them. Instead, one of Epstein’s staff provided information. Then in 2005, Bank 1’s Senior Executive 1, supported another friend of Epstein as a private client. Her name was Ghislaine Maxwell. She was Epstein’s ex-girlfriend and remained entwined in his life. “Ghislaine is a good friend of one of our very big clients in the US,” Senior Executive 1 wrote. “Can we please try to help her.” At Another third Bank, a loan of $20 million provided in 2001 had not been repaid and Epstein had litigated and the case was settled in 2005, but it’s likely the relationship with that other Bank came to an end then.
By 2006 Epstein’s estimated net worth was likely somewhere around $500 Million, with perhaps bankable assets in the hundreds of millions of dollars. Whilst he had accounts at Bank 1 he also had accounts elsewhere too. Whilst it had taken him 25 years to make this fortune, a substantial portion of the original seed money for his wealth as well as much if the the principal, including many of the property assets could well have been acquired from the proceeds of crime (Towers Financial Fraud/Defrauding Wexner), however it appears no one suspected this at the time.
2000’s Summary – Part 2 2006 – 2010:
During this period, Epstein’s main income from his relationship with and as financial adviser to the billionaire retailer Les Wexner, would come to a swift end as would much of his ability to make new money. This was due to Epstein’s arrest in June 2006, being publicised and the nature of the charges relating to the sexual abuse of minors, although these charges were initially denied by Epstein.
A review in October 2006, at Bank 1 of his banking, asset and credit accounts with balances totalling just $32 million, and “cash withdrawals are routinely made in amounts for $40,000 to $80,000 several times a month, which total over $750,000 year to date,” the review reported. Bank 1 reclassified Epstein as “High” risk. Bank 1 considered exiting Epstein, with Compliance in favour, but senior management, led by Senior Executive 1 and Senior Executive 2 deciding to keep the account, and only act on a “reactive, client service basis,”
During 2007, Epstein’s lawyers agree a very generous Non Prosecution Agreement (NPA), dealing with potential serious multiple federal charges for him and his co-conspirators and so in 2008, Epstein pleads guilty to “procuring a child for prostitution and sex trafficking” and is given 18 months imprisonment and officially registered on the sex offenders register. Epstein was to serve 13 months, starting July 1, 2008.
Despite pleading guilty, Bank 1 decided to still retain Epstein as a client, with Senior Executive 1 discussing the case with the Banks Group General Counsel. This despite Bank 1’s AML team filing the 4th SAR related to Epstein a month later on 15 August 2008 related to US$800,000 of suspicions transactions for the period 18 January 2007 – 16 June 2008, which included the period between Epstein’s arrest and his imprisonment. Since 2002, Bank 1 filed 4 SAR’s covering periods where suspicions arouse in 2002 and 2003 and 2007 and 2008, amount to US$3.085,900 in suspected transactions, probably some of which related to cash transactions, but this information is not fully disclosed. It was also in 2007, that a first Epstein victim filed a lawsuit which was done in New York accusing Epstein of abusing her when was she was 16. The lawsuit was dismissed in 2008, with the victim settling for US$28,000. This could have been paid out of Epstein’s accounts at Bank 1 or elsewhere.
Another account of Epstein’s at a third bank was used to pay Ghislaine Maxwell $7 million in June 2007 so that Maxwell could purchase a helicopter, which would be used to transport guests from the airport in USVI to the Epstein Island. This indicated it wasn’t only Bank 1 who had decided to retain Epstein’s as a client, but as at June 2007, so had the third bank too.
Nevertheless, his main revenue source, Les Wexner cuts business ties with Epstein in 2007 and another billionaire relationship was also affected, as Epstein is forced to stand down as a director of the (Leon) Black Family Foundation also in 2007. Lex Wexner has since claimed he had identified by 2008 that Epstein had been stealing from him and settled with a repayment of $100 million from Epstein. From 2007 to 2012, Financial Trust Company, Epstein’s main business at that time, generated less than $5 million in fees, according to reports. From 2008 to 2012, Financial Trust recorded $166 million in net losses mainly due to losing his best client (Les Wexner) and losses from the financial crises.
By 2010 Epstein’s estimated net worth was likely somewhere around $350 Million, with perhaps bankable assets in the hundreds of millions of dollars.
2010’s Summary – Part 1 2010 – 2015:
By 2010, Epstein was out of prison, but it was clear to even Senior Executive 1 who had defended Epstein, because he had still claimed his innocence, that Epstein had lied to him in 2006 about the ages of the complainants. Not just because of the guilty plea, but more likely because of the now numerous civil complaints filed against Epstein in 2008, 2009 and 2010 that were brought by multiple women related to a time when they were minors. The age of consent in New York is 17, whereas in Miami and the US VI it is 18.
In 2011/2012, Bank 1 had Epstein’s estimated net worth still at around $500 million and even approved $50 million of additional credit to facilitate market trading by Epstein. By now, he had about $212 million at the bank, nearly half of his estimated net worth.
Whilst Lex Wexner was gone, Epstein put all his efforts into persuading Leon Black, a Hedge Fund billionaire to hire him as an adviser. In 2011, Epstein established his new business the Southern Trust Company in the USVI which became his main revenue generating company. A second tax agreement was agreed in the USVI for 2013-2023.
In 2012, Leon Black agreed to hire Epstein. Black and Epstein agreed to a $23.5 million payment for his services in February 2013 and negotiated a further $56.5 million three months later, paid out in instalments, with Black paying Epstein a total of $50 million in 2013. According to financial records, those payments from Black made up nearly all of the $51 million in fees that Southern Trust earned that year. In 2014, Black agreed to pay Epstein for his services on an “ad hoc basis” without a written agreement. Black paid him $70 million in 2014 for his advice on estate and tax planning, audits, and managing his art collection, family office, yacht and airplane. Black’s payments made up the entirety of Southern Trust’s fee income in 2014. Black paid Epstein $30 million in 2015 which made up more than half of Southern Trust’s fee income in 2015.
In 2015, Epstein invested an estimated US$1.5 Million into a business startup led by former Israeli PM Ehud Barak, called “Carbyne” which is an emergency services technology company.
Had Epstein’s behaviour changed as regards women and girls?
Employees in Bank 1’s AML department in 2010 learned from media reports that the Justice Department was investigating Jean Luc Brunel’s MC2 modelling agency for feeding Eastern European girls and women into Epstein’s suspected sex-trafficking network (Brunel had opened accounts at Bank 1 introduced by Epstein). Plus, there were Epstein’s regular wire transfers, the credit cards and bank accounts he requested for teenagers and young women and his voluminous cash withdrawals. For example, Epstein had sent about $450,000 to an 18-year-old. Bank 1’s Head of AML compliance was especially alarmed. A year later he was promoted to become Bank 1’s Head of Compliance. He recommended an exit but senior management, argued against it and it didn’t happen, mainly because of Senior Executive 1. By July 2011, the Bank’s General Counsel was also recommending an Epstein exit, but Senior Executive 1 also intervened. After meeting with Epstein twice and due to the support he still had from Senior Executive 1, the Group GC did not force an exit.
Still once Epstein’s personal Bank 1 private client adviser left for Bank 2 in 2012 and Senior Executive 1 left Bank 1 in 2012 the writing was on the wall for Epstein and in August 2013, Bank 1 decided to exit the Epstein relationship. This could well have followed the filing of the 5th Bank 1 SAR on 8 August 2013 and related to US$920,000 for the period 13 January 2009 – 31 July 2013. All 5 SAR’s cover filings from 2002 – 2013 and cover periods where suspicions arose in 2002 and 2003 and 2007 and 2008 & 2009 – 2013 representing suspicions raised in 9 out of 15 years amounting to US$4,005,900 in suspected transactions by value, probably much of which related to cash transactions, but this information is not disclosed, though according to additional reporting, “between 2003 to 2013 Epstein’s accounts had more than $3.5 million in cash withdrawals”.
Bank 2 would open accounts for Epstein with $176 million arriving in October 2013. According to reports Bank 2 conducted due diligence on Epstein prior to onboarding. A memo sent to senior Bank 2 management noted Epstein’s 2008 criminal conviction, his 18-month prison sentence and 17 out-of-court civil settlements linked to the conviction. The business opportunity identified Epstein investments of $100-300 million generating revenues of $2-4 million. In January 2015, Bank 2’s Reputation Risk Committee (RRC) considered the Epstein accounts with the decision being they were “comfortable with things continuing” but with some conditions that transactions shouldn’t be suspicious, unusual or too complex.
In December 2015, Senior Executive 1 was announced as the new CEO of a Foreign Bank, with that Foreign Bank informing Senior Executive 1 to cut ties with Epstein.
In May 2015 a memo written by the Drug Enforcement Agency (Organised Crime Drug Enforcement Task Force “OCDETF”), confirmed the existence of an investigation (Operation Chain Reaction) into Epstein and 14 potential Co-conspirators which had started on 17 December, 2010. In the memo it is stated that, the “DEA indicates the above individuals [Epstein plus 14 others], are involved in illegitimate wire transfers which are tied to illicit drug and/or prostitution activities occurring in the USVI anda NYC”. This memo is heavily redacted to protect in particular the other 14 persons, but not as much as for Epstein. In the memo it reveals 3 transactions, (currency Transaction Reports or “CTR’s”) filed by Bank 2 (CTR 1 – $20,723 payment out on 15 November, 2013; CTR 2 – $21,150 payment out on 19 December 2013, and CTR 3 – $60,775 payment out on 31 January, 2014). It also reveals many SAR’s and CTR’s related to Epstein’s associates from Bank’s between 2012 and 2015 with one SAR filed on associates in 2012, 2013 and 2014. In 2015 9 associates were included in numerous SAR’s relating to amounts in excess of $4 million. These SAR’s may have come from Bank 1 or Bank 2 but also third Banks. Epstein is the subject of 7 SARs (1 in 2013, 2 in 2014 and 4 in 2015) totalling $5,672, 921. In total 14 (including Epstein) of the 15 targets investigated by the DEA are the subjects or included as included in SARs filed during this period. The Memo reveals additional bank relationships. Two in Paris (one at a major, French Bank in Paris, one Paris branch of a Belgian Bank and another Paris branch of a Global British Bank as well as a Geneva branch of the same bank, and. small Swiss bank in Zürich.
2010’s Summary – Part 2 2016 – 2020:
In 2016, Epstein paid an estimated $20 million to purchase a larger, neighbouring island called Great St. James, in the US VI. He also invested about $40 million in a VC firm co‑founded by a Silicon Valley billionaire that focused on fintech startups. That investment would grow to be worth about $170 million in 2026 and is still part of the deceased’s estate. His main source of revenue, Leon Black doesn’t appear to have paid Epstein any money in 2016, and Southern Trust didn’t report any fee income for that year. In 2017, Black made his final payment to Epstein of $8 million – the only fees that Southern Trust reported receiving that year. Also in 2017, Epstein sells his Boeing 727, which becomes known as the “Lolitta Express”.
Whilst accounts at Bank 1 were closed a 6th SAR was filed on 1 September 2016 and related to US$157,898 for the period 4 January 2006 – 8 June 2007. Also in 2015, a third bank opened accounts for Jeffrey Epstein’s trusts in 2015 but closed them in 2017 – (an account was also opened in 2019 and closed quickly afterwards).
A class action lawsuit was brought against Epstein by Hoffenberg (ex Towers Financial) and others in 2016, which alleged that the millions in stolen investments via Towers Financial were the seed capital for Epstein’s wealth. Hoffenberg was now released from prison after spending 18 years for the Ponzi scheme fraud he alleges Epstein masterminded. The judge threw the case out claiming the main perpetrator couldn’t bring a class action case against anyone.
Also in 2016, Bank 2’s AML Compliance team file its first suspicious activity report. In the spring of 2017, Bank 2’s compliance staff discussed the constant cash withdrawals and their reporting obligations with Epstein’s lawyer. Nevertheless, Epstein’s lawyer reassured Bank 2 that all was well, and Bank 2 continued to permit the cash withdrawals. In 2017, on one occasion, Epstein’s lawyer withdrew $100,000 in cash explaining it was needed for tipping and household expenses. Over a four-year period, the lawyer withdrew $800,000 in cash. Between 2013 and 2017, Epstein’s personal lawyer withdrew $7,500 in cash two or three times per month from Bank 2’s New York branch. In total, there were 97 such withdrawals. The bank’s limit for withdrawals by a third party on an account was $7,500. When queried, the lawyer explained the payments were for travel, tipping and expenses. Bank 2 filed its second suspicious activity report in 2017. “Given that this is the second time this has occurred, we should have a discussion about the future of this account,” one Compliance officer wrote. But no action was taken. Bank 2’s supervisor later determined that Epstein was on average withdrawing $200,000 in cash a year from Bank 2. It said that while it was unclear whether it was used “to cover up old crimes, to facilitate new ones, or for some other purpose”, Bank 2’s lack of recognition of the risk constituted “a major compliance failure”. Payments to young women in eastern Europe and Russia also prompted internal debate. Bank 2’s Compliance team in March 2017 considered a review of Epstein’s accounts after he said one beneficiary of a wire transfer was a “Russian model” based in Moscow. But they decided against it, with one team member explaining that because “this type of activity is normal for this client it is not deemed suspicious”, while confirming the woman had an online modelling profile.
In November 2018, the Miami Herald published articles titled “Perversion of Justice”, which called into question the lenient treatment given to Epstein in 2008. The Herald conducted dozens of interviews with Epstein’s alleged victims, and made Freedom of Information Requests to law enforcement agencies and looked through relevant court papers, realising their must have been a plea deal which was sealed (confidential). When they revealed the results of their investigative work, their findings sparked widespread outrage.
Federal prosecutors, including those in the Southern District of New York began reviewing the 2008 NPA (the plea deal) and realised the deal only applied to acts in Florida by Epstein and covered conduct between 2001 – 2007. This allowed them to pursue a legally independent federal case in New York. They had to gather new victim accounts, including cases outside Florida, but did not look for any new evidence beyond 2007. In fact no investigation appears to have been carried out on Epstein’s activities after this date.
In early 2018, Bank 2 was holding close to $225 million for Epstein across dozens of accounts. He was also classed by Bank 2 as politically exposed over his “close relationship” with both former US president Bill Clinton and Andrew Mountbatten-Windsor. By December 2018 and after internal discussions at Bank 2, the decision to exit Epstein was made and he was notified on December 21 And given until end of February 2019 to move the funds elsewhere. The exit took longer with extensions granted into April and May. There was still small account balances on the Bank 2 account on July 6 2019.
In 2019 a New York grand jury delivered a 2 count indictment on July 2, which led to Epstein’s arrest in July 6th, aged 66. The indictment contained 2 felony charges, i) conspiracy to commit sex trafficking of minors, and ii) sex trafficking of minors. The first charge carried a maximum sentence of 5 years in prison whereas the second carried a maximum sentence of 40 years in prison. The indictment alleged that, “between 2002 through 2005, Epstein sexually exploited and abused dozens of underage girls by enticing them to engage in sex acts with him in exchange for money. Epstein allegedly worked with several employees and associates to ensure that he had a steady supply of minor victims to abuse, and paid of those to recruit other underage girls to engage in similar sex acts for money. He committed these offences in New York and Palm Beach, Florida”.
Epstein was arrested on July 6 2019 on federal charges for the sex trafficking of minors in Florida and New York. Epstein pleaded not guilty in his initial appearance in an SDNY federal court. He was denied bail in part because he was considered a flight risk given his wealth, connections and prior conduct. The case was set for trial in 2020. Epstein committed suicide on August 10, 2019.
On 8 August he made a new Will, leaving all his assets, estimated at US$577 Million to “The 1953 Trust”, likely named after the year of his birth. The net asset valuations are based on cash at US$56.5 Million, Securities US$127 Million, Property Assets at US$184 Million, Hedge Funds and Private Equity Investments at US$195 Million and Aviation, Automobile and Boat Assets at US$18.5 Million. The executors and Trustees of The 1953 Trust were Darren K Indyke (long time Epstein’s lawyer) and Richard D Kahn (long term Epstein accountant). As regards property assets, Epstein owned a palatial townhouse on the Upper East Side of Manhattan worth more than $50 million. He also owned a mansion in Palm Beach, Florida, worth about $12 million; a ranch in New Mexico valued at just over $17 million; and an apartment in Paris worth an estimated $8.6 million. His two private Caribbean islands (Great St. James and Little St James) were together valued at $86 million.
Two days later, on 10 August, Epstein died, taking his own life by hanging in prison, awaiting trial.
The USVI authorities have since removed Darren K Indyke (long time Epstein’s lawyer) and Richard D Kahn (long term Epstein accountant) as executors and trustees and a court appointed administrator is responsible for dealing with the Estate.
More on Suspicious Activity Reports
Whilst Bank 1 filed 9 SAR’s in total, 5 were filed during the period of the account being opened (1985 -2013) and related to approximately $4 million, likely suspicious cash withdrawals. A 6th SAR was filed in September 2015 and related to US$157,898 (for the period 4 January 2006 – 8 June 2007) and a 7th SAR filed in September 2016 and related to US$152,626 (for the period 28 January 2015 – 24 September 2015). After Epstein’s arrest in 2019, Bank 1, filed an 8th SAR on 13 August 2019 related to US$200,979,535 for the period 1 October 2003 – 29 May 2019 and on 26th September 2019: a 9th SAR related to US$1,081,819,653 for the period 1 October 2003 – 29 May 2019, which are likely to be defensive filings and may relate to third party transactions related to Epstein at a third bank with a Bank 1 client or via correspondent banking, as Epstein was exited as a direct relationship in August 2013.
Bank 2 filed 2 SAR’s one in 2016 and one in 2017. Whilst no equivalent details have been released compared to those for Bank 1, AML Compliance were clearly concerned about cash withdrawals and the regulator, has reported that on average cash transactions for Epstein accounts averaged $200,000 a year over 4 years.
These and other Bank SAR’s were reviewed by the DEA in their 2010 – 2015 investigation. Epstein is the subject of 7 SARs (1 in 2013, 2 in 2014 and 4 in 2015) totalling $5,672, 921. In total 14 (including Epstein) of the 15 targets investigated by the DEA are the subjects or included as included in SARs filed during this period.
Epstein Associates
Jean Luc Brunel: Brunel was a French modelling agent, and founder of MC2 Model Management, a modelling agency financed by Epstein. Brunel and Epstein reportedly become close associates in the 1990’s, and Epstein set him up as an independent modelling agency in the mid 2000’s. He is alleged to have recruited models and minors for Epstein. Prior to linking up formally with Epstein, Brunel had been a leading model scout for a French( modelling agency, and claims by CBS 60 minutes in 1988 were that his agency had been involved in drugging and abusing young models. Following Epstein’s arrest in July 2019, Brunel becomes a focus of French law-enforcement. In December 2020 he was arrested in France on charges of sexual assault and rape of minors connected to Epstein’s network. Whilst awaiting trial in France for alleged sexual abuse, Brunel is found dead in prison reported committed suicide in February 2022.
Lesley Groff: Lesley Groff worked for Jeffrey Epstein from approximately 2001 to 2019, serving as his executive assistant for nearly two decades. During this time, she managed his daily operations, travel, and communications. Groff was one of 4 staff members named as an unindicted co-conspirator in Epstein’s 2008 non-prosecution agreement. She was also listed as one of eight “suspected co-conspirators” by the FBI in 2019, alongside Ghislaine Maxwell and others. Victim testimony identified her as one of the staff members, along with Kellen and Maxwell that young women had to report to. She has not been charged with any crimes.
Darren Indyke: Long time lawyer for Epstein from the late 1990’s to 2019 and then appointed as a Co executor of Epstein’s estate. He helped establish trusts and corporations for Epstein and had directorships and signing authority on a number of Epstein companies. Named as executor and Trustee of Epstein’s estate. A 2024 lawsuit brought against the Epstein Estate was settled in February 2026. The case alleged that 2 of Epstein’s closest advisers aided and abetted Epstein in his sex trafficking of young women and teenage girls. The lawsuit said “Induce and Kahn Helped Epstein create a complex web of corporations and bank account that let Epstein hide his abuses and pay victims and recruiters”. Both were “richly compensated” for their work. No admission of wrongdoing was made in settling the case. He has not been charged with any crimes.
Richard Kahn: Long time accountant for Epstein from the late 1990’s to 2019 and then appointed as a Co executor of Epstein’s estate. He established trusts and corporations for Epstein and oversaw his tax strategy and filings. A 2024 lawsuit brought against the Epstein Estate was settled in February 2026. The case alleged that 2 of Epstein’s closest advisers aided and abetted Epstein in his sex trafficking of young women and teenage girls. The lawsuit said “Indyke and Kahn Helped Epstein create a complex web of corporations and bank account that let Epstein hide his abuses and pay victims and recruiters”. Both were “richly compensated” for their work. No admission of wrongdoing was made in settling the case. He has not been charged with any crimes.
Sarah Kellen: Sarah Kellen (Sarah Lyn Kensingtn – later Sarah Kellen Vickers) worked for Epstein in the early 2000s, aged 22 or 23 until 2019, initially as an assistant in his Manhattan office. Kellen’s responsibilities reportedly included scheduling “massages”, coordinating travel, etc. Kellen was named as an unindicted co-conspirator in Epstein’s 2008 non-prosecution agreement and has been referred to as a “knowing participant in the criminal conspiracy” by a federal judge in the Ghislaine Maxwell trial. He also stated that “[Maxwell] was Epstein’s number 2 and the lady of the house”, but “at some point Kellen took over some of [Maxwell’s] duties”. Victims, including Virginia Giuffre, have accused Kellen of facilitating abuse and recruiting victims. Other claims are that Kellen paid the victims after the “massages”. Kellen has claimed to be a victim of Epstein’s abuse and received compensation from the Epstein Victims’ Compensation Program. SK was struggling financially and emotionally when she began working with Epstein in 2002. In 2015 she married NASCAR driver Brian Vickers but divorced in 2025. She works as an interior decorator. She has not been charged with any crimes.
Nadia Marcinko: A Slovak born model and pilot, identified in civil cases as a long term associate Epstein, living in properties owned by Epstein and travelling on Epstein’s private planes. She appears to be associated with Epstein first when she was brought to the US (perhaps via Jean Luc Brunel’s modelling agency) and became part of Epstein’s inner circle when she was 18 in 2003, though some victims have stated it coukd have been 2002 when they also met her, when she was 17. She was granted immunity under the 2008 non-prosecution agreement negotiated by federal prosecutors. Marcinko trained as a pilot with Epstein paying for her training. After 2008 and to 2010, it appears she tried to sever ties with Epstein. By 2011 however, she had her own airline company and even piloted again for Epstein. During her time working for Epstein some civil cases claimed that she helped arrange travel or accommodation for young women and others claimed she acted as a recruiter or facilitator. In other materials her name appears in Epstein flight manifests, scheduling records and travel documentation. She has invoked the 5th amendment repeatedly when questioned about Epstein’s conduct in civil cases. In 2018 she reportedly reached out and co operated with US authorities to provide information on Epstein’s and Maxwell and is considered more a victim of human trafficking rather than a Co conspirator. She has not been charged with any crime.
Ghislaine Maxwell: Socialite and former girlfriend and confidant of Epstein. Maxwell meets Epstein socially, likely in New York City through elite social circles on or about 1991, at the same time as the year her father Robert Maxwell died. In the mid‑1990s,Epstein and Maxwell had a romantic relationship which lasted several years before becoming more of a professional partnership. By 1998–1999, Maxwell begins a more formal role managing Epstein’s household and property affairs. She handled staffing, logistics, and social introductions. Maxwell’s role expanded from social companion to de facto manager of Epstein’s estates and personal network. During this period Epstein renamed a Palm Beach company after her. Between 2000–2004, US Prosecutors later alleged Maxwell participated in recruiting minors for Epstein during the early 2000s (charges spanning from 1994 were part of later indictments). During much of the 2000s, Maxwell was seen as a central figure in Epstein’s circle, managing properties and events and networking with powerful individuals. When Epstein was convicted of soliciting prostitution from a minor in 2008, Maxwell was not named as an unindicted co-conspirator in Epstein’s 2008 non-prosecution agreement. Maxwell’s public profile decreased after this point, but she remained connected to Epstein socially and financially even if not constantly in the spotlight. After this conviction, Maxwell focused on philanthropic and public work (including her TerraMar Project founded in 2012) while maintaining ties to Epstein’s network. Her name appeared in flight logs and correspondence with Epstein after 2010. On July 2, 2020, Maxwell was arrested by the FBI in New Hampshire. On December 29, 2021 – Maxwell was convicted on five federal counts of sex trafficking and related offences for her role in assisting Epstein. In particular, the indictment stated that “from at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated in Jeffrey Epstein’s abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that their victims were in fact minors”. It also stated that, “MAXWELL and Epstein’s victims were groomed or abused at Epstein’s residences in New York, Florida, and New Mexico, as well as MAXWELL’s residence in London, England”. On June 28, 2022 – Maxwell was sentenced to 20 years in federal prison.
Alfredo Rodriguez: He was Epstein’s Palm Beach house manager (butler) from November 2004 through May 2005. As house manager, his duties included, acting as butler and household staff, Chauffeuring and running errands, Overseeing domestic operations for Epstein and his guests, Providing hospitality for visitors to the estate (including those arriving for “massages”). Staff at the mansion testified he was instructed to handle cash on hand and interactions with some of the women who came to the property. Rodriguez later gave a sworn deposition recounting what he saw inside the Palm Beach home, including the arrival of young girls and activities that were part of the later civil and criminal cases. Rodriguez became widely known because he took possession of Epstein’s personal contact book — often called the “little black book.” He secretly kept a copy of the book containing hundreds of contacts after leaving Epstein’s employ. In 2009, Rodriguez attempted to sell that book for about $50,000 to what he believed was an attorney for Epstein victims — but the person was actually an FBI undercover agent. Because he withheld potentially important evidence and tried to sell it instead of turning it over, he was charged with obstruction of justice. Rodriguez pleaded guilty to obstruction of justice related to his failure to surrender the contact book. In 2010, he was sentenced to 18 months in federal prison. Reports indicate he died of mesothelioma (a form of cancer) around 2014–2015, shortly after completing his sentence.
Adriana Ross: Adriana Ross, also known as Adriana Mucinska, was a Polish-born former model who met Epstein and then became a household assistant to from 2001 – 2007. She was identified as a potential co-conspirator in Epstein’s sex trafficking operation and was one of four women named in Epstein’s 2008 Non-Prosecution Agreement, receiving immunity from federal prosecution. Ross managed Epstein’s daily massage appointment book, scheduling encounters with young women and girls. She was a frequent passenger on Epstein’s private aircraft, appearing on at least 24 flight logs alongside Epstein’s inner circle. Ross invoked her Fifth Amendment right against self-incrimination over 100 times during a 2010 civil deposition. Ross’s involvement in Epstein’s network has been documented in various court filings and investigations. She has not been charged with any crime.
Haley Robson: Haley Robson was identified in the 2005–2008 Palm Beach investigation which led to epstein’s arrest and conviction. Law enforcement described her as one of the young women who helped recruit other girls to Epstein’s Palm Beach residence, including the one who recruited the 14 year old girl whose mother complained which set off the 2005 investigation. Court documents indicated she received payments for bringing other girls. She was granted immunity under the 2008 non-prosecution agreement negotiated by federal prosecutors. The primary conduct associated with her involvement occurred mainly 2004–2006.
Emmy Taylor: Ghislaine Maxwell’s personal assistant from the 1990’s. She was born in 1975 in the UK. She has been identified as accompanying Maxwell on plane trips with Epstein. One Victim has also claimed Taylor showed her how to massage Epstein at his Palm Beach mansion. Several victims claimed Maxwell refers to Taylor as her “slave”. She has not been charged with any crime.
Larry Visoski: Epstein’s long term pilot from the early 1991 until 2019, including piloting the infamous “Lolitta Express”. Visoski was called as a witness in the 2021 trial of Maxwell, where he testified about his experience, flying the planes and what he did or did not see during the flights. In that testimony, he denied ever witnessing sexual activity on the flights, noting that the cockpit door was typically cone closed when passengers were on a board. He has not been charged with any crime.
Note: For more details, see the detailed 51 page Appendix, available privately on request.
This Case study summary has been compiled using publicly available information, including news and media reports and articles, and from published Books in particular of victims, court case allegations and defences and testimony. It is also a summary, which by its nature will not include all materials and is highly selective. No doubt some if not a lot of this could be contested and alternative opinions, and evidence provided in order to question and challenge the contents of the information in the public domain. As a result the reader is encouraged to keep a very open mind and to consider this summary in that light. The author does not presuppose this summary to represent anything other than a short condensed summary of some publicly available information.
Whilst allegations and claims have been made against a number of persons, at the same time denials of responsibility and accountability have also been made and all persons should be treated and considered as innocent until proven guilty.
Financial Crime News, March 2026














