Epstein Data Wiki

Southern Trust Company, Inc.

Properties2
tagsentity, virgin-islands, epstein-company, banking
aliasesSouthern Trust Company, Southern Trust Company Inc, Southern Trust, STC, Financial Informatics, Inc.

35 min read

TypeCorporation, U.S. Virgin Islands1
IncorporatedNovember 18, 2011; the Government of the Virgin Islands pleads that it was incorporated as Financial Informatics, Inc. and renamed in September 201223
Address6100 Red Hook Quarter B3, St. Thomas14
ShareholderJeffrey E. Epstein, sole shareholder15
Account signatoriesEpstein, Darren Indyke, Harry Beller, Jeanne Brennan1
SubsidiarySouthern Financial, LLC, organised February 25, 2013; Southern Trust its sole member62
PredecessorFinancial Trust Company, Inc.75
BanksFirstBank (2012–2019); JPMorgan Chase (2013–2014); Deutsche Bank (2013–2019); Charles Schwab (2019)891011
Employees declared to Deutsche Bank412
LitigationNamed defendant, Government of the Virgin Islands v. Estate of Jeffrey Epstein3

Southern Trust Company, Inc. was a United States Virgin Islands corporation wholly owned by Jeffrey Epstein and, from 2013, the company through which his Virgin Islands operation was staffed, banked and paid.14 It succeeded Financial Trust Company, Inc. in that role in the spring of 2013 and held as its own subsidiary Southern Financial, LLC, the entity that received Financial Trust’s securities.713 Deutsche Bank grouped the accounts of the two companies with Epstein’s own and those of other Epstein entities under the internal label “Southern Financial Relationship,” which by September 2019 covered 76 accounts, 42 of them capitalised.14 The Government of the Virgin Islands named the company as a defendant in its action against Epstein’s estate, alleging that it did not perform the business it had described to the territory’s Economic Development Commission.315

Formation and name

Deutsche Bank’s know-your-customer file gives the company’s date of incorporation as November 18, 2011 in the U.S. Virgin Islands, and the same date and the address 6100 Red Hook Quarter B3 appear in the account-opening particulars Jeanne Brennan sent the bank on March 14, 2013.12 Asking for the outstanding account-opening documents on June 12, 2013, a Deutsche Bank associate wrote that the articles of incorporation she had been given were those of Financial Informatics, Inc., that they showed the company formed by three named individuals, and that they “do not mention Jeffrey Epstein having authority over the account.”16

The Government of the Virgin Islands’ amended complaint against Epstein’s estate pleads the connection directly: the company “was originally incorporated in the Virgin Islands on November 18, 2011 as Financial Informatics, Inc., but changed its name to Southern Trust Company in September 2012.”3

What the company said it did

The nature of the business given to Deutsche Bank was “Consulting Services relying on Financial and Biomedical algorithms,” expanded in the bank’s own record to: “Southern Trust is a private consulting company that invests the assets of their clients and gets their revenue from the return of these investments. Southern Trust invests in different portfolios catered to their clients and makes their revenue based on the returns and the fees associated with managing their clients assets.”2112 The same file records four employees, business transacted only in the U.S. Virgin Islands, estimated gross receipts of $2,000,000 a year and estimated net profit of $1,500,000.12

An undated internal organisation chart describes the company’s actual function in the territory: “STC is the Administration office for LSJE which controls Purchasing, Vendor payments, Expense tracking, Staff payroll and Contractor(s) payments.”4 It lists five staff at the Red Hook office alongside the New York office of HBRK Associates: Cecile de Jongh as office manager and Jeanne Brennan as head accountant, with an accountant for LSJE, an accountant for the company and an IT manager, who are not named here.4

Southern Financial, LLC

Southern Financial, LLC was organised in the Virgin Islands on February 25, 2013 at the same Red Hook address, with Southern Trust as its sole member and Epstein, as sole shareholder of Southern Trust, as ultimate beneficial owner.265 Deutsche Bank’s know-your-customer sheet records its purpose: “This business is funded by Jeffrey Epstein’s wealth. This company was formed to hold Mr. Epstein’s personal wealth and invest in different ventures.”6 The same file records that the new company’s “initial funding in February 2013 was $1,000 from the sole shareholder of the sole managing member (Jeffrey Epstein).”17

An enhanced due diligence review completed on December 19, 2014, prompted by a request to open a global markets relationship for Southern Financial, classified the company as a high-risk private investment vehicle and set out the negative information the bank’s screening had returned about Epstein.5 Its author approved the account “with the condition to mark the relationship as High Risk and the recommendation to be monitored for suspicious activity,” but added that the information about the beneficial owner “may pose reputational risk to DB” and recommended “escalating this case to the Americas Reputational Risk Committee for review and decision.”5

Succession from Financial Trust Company

On March 22, 2013 Cecile de Jongh wrote to Epstein: “We are wrapping up converting from FTC to STC.”7 The message concerned accrued vacation and roll-over days, which she proposed to settle in the Financial Trust termination letters “so we can start with a clean slate with STC in April - it will look better re EDC,” putting the aggregate at $13,711.54; Epstein replied the same evening, “please provide details.”718

On March 29, 2013 eight securities positions were delivered out of Financial Trust’s JPMorgan investment account to Southern Financial by free delivery: Lloyds TSB Bank PLC MTN, Ally Financial preferred, Ariad Pharmaceuticals, Bank of America preferred, Biogen Idec, Cliffs Natural Resources convertible preferred, Dean Foods and a Deutsche Bank exchange-traded note, with transaction market values from $112,020.00 to $3,390,348.00.13 Clearing an overdraft left in the old account, a JPMorgan associate wrote on April 24, 2013 that “All assets have been moved to Southern Financial as of yesterday,” attributing the overdraft to the settlement of a foreign exchange forward; the bank was told to cover it from Southern Financial.19 The Dechert report records a further asset making the same journey: 263,257 shares bought by Financial Trust in Apollo Global Management’s 2011 initial public offering “appear to have later been transferred to a second Epstein entity, Southern Financial LLC, and appear to have been held through at least September 2019.”20

Banking

FirstBank

Answering a grand jury subpoena from the U.S. Attorney’s Office for the Southern District of New York on March 9, 2020, FirstBank in San Juan listed two Southern Trust Company commercial checking accounts: one opened December 7, 2012 and closed October 18, 2019, with Epstein, Darren Indyke and Jeanne Brennan-Wiebracht as authorised signatures, and one opened February 22, 2013 and by then restricted to “credits only allowed,” with Indyke, Cecile de Jongh, Brennan-Wiebracht and Epstein as signatures.8

JPMorgan Chase, 2013–2014

JPMorgan’s remittance record for the company gives “DATE OPENED: 03/14/2013.”9 In the same weeks the Epstein office asked JPMorgan’s private bank to issue the company a business credit card with a $50,000 limit, offset by reducing the limit on another Epstein company’s card so that, as the private banker put it, “the credit exposure of Jeffrey Epstein will not be increased”; the bank recommended the Ink Plus card, and the proposed sub-limits were $25,000 for Epstein, $15,000 for de Jongh and $10,000 for Brennan.21 The request went to a JPMorgan executive for endorsement on April 2, 2013; the documents cited here do not establish whether the card was issued.22

In September 2013 the bank sorted the two companies’ positions between those to remain at JPMorgan and those to be transferred to Deutsche Bank by ACAT, with a separate account for each side of the split.23 A letter dated September 30, 2013 in Epstein’s name authorised the transfer of “the entirety of Southern Financial, LLC’s checking account” to Deutsche Bank, with the amount written in by hand as $329,920.88 and a manuscript note recording that the balance was confirmed with Harry Beller and Jeanne Brennan on October 2.24 A bank summary of the cash then held put Southern Financial’s brokerage cash at $14,454,510.95, a second Southern Financial balance at $329,920.88, the company’s checking balance at $372,921.98 and its savings balance at $18,755,048.50.25 On October 16, 2013 the bank was instructed to move $6 million from the savings account to Deutsche Bank, and first to move $4 million from a brokerage account into savings to collateralise derivatives.26

The relationship closed the following winter. A JPMorgan internal email of February 18, 2014 confirms “that all trades for Southern Financial and Southern Trust have either matured, been unwound or have been transferred to DB” and tells the team to move the remaining cash and close the accounts, listing $4,003,093.20 for Southern Trust as completed that day, $911,807.66 in a second Southern Trust account and $10,397,099.07 for Southern Financial.27 The wire instructions recorded on the same page route the $911,807.66 and the $10,397,099.07 through The Bank of New York to Pershing LLC for further credit to the two companies.27

Deutsche Bank, 2013–2019

Deutsche Bank opened the companies’ accounts between August and October 2013. Its September 2019 presentation to the U.S. Attorney’s Office lists, for Southern Trust, a brokerage advisory account opened August 19, 2013 “to hold marketable securities & cash,” a checking account and a money market account opened August 27, 2013, and a DBAGNY Preferred Deposit account opened February 21, 2017; and for Southern Financial, a brokerage advisory account opened August 19, 2013 “to invest long term with the bank,” a checking account opened September 5, 2013, a second brokerage account opened October 29, 2013 and a DBAGNY Preferred Deposit account opened February 27, 2017.10

The release holds a draft schedule to a 2002 ISDA Master Agreement naming Deutsche Bank AG as Party A and “Southern Trust Company, Inc., a corporation incorporated under the laws of United States Virgin Islands” as Party B; the copy is marked DRAFT and its date line is blank.28 A termination agreement dated as of December 7, 2016 between Deutsche Bank AG and Southern Financial ends a Global Master Repurchase Agreement of January 7, 2015, reciting that no transactions were outstanding under it; the signature blocks on the copy in the release are blank.29

In July 2018 the bank began a periodic review of high-risk accounts covering Southern Trust, Epstein personally and Zorro Management under the “Southern Financial Relationship” label.30 The outstanding items, sent to the relationship team in August and September 2018, included the purposes of several accounts, certificates of good standing for Southern Financial and LSJE, expired identification documents for Indyke and Brennan, and a discrepancy in a signatory’s name: the corporate resolution and signature card from 2017 read “Jeanne Brennan” while her driving licence read “Jean Anne Brennan”; the bank asked for an updated resolution.31 Whether the resolution was provided is not established by the documents cited here.

By the following summer the bank was ending the relationship. Asked on June 10, 2019 when the relationship would be off-boarded, a Deutsche Bank director replied: “This client is in the process of being offboarded.”32 The Butterfly Trust money market account was closed on July 8, 2019 “in connection with the offboarding of the Southern Financial Relationship.”33

Charles Schwab and the July 2019 suspicious activity report

Southern Trust opened a corporate brokerage account at Charles Schwab in April 2019, with Richard Kahn as the authorised agent and Epstein listed as an internal control person and 100 percent beneficial owner without authority to act on the account.11 The Charles Schwab Corporation filed a suspicious activity report on July 13, 2019 reporting “concerns with attempted wires for the purpose of real estate, in light of negative media surrounding Jeffrey Epstein,” and put the total of the outgoing wires of concern at $27,658,324.1134

The report describes two attempts. On June 26, 2019 Schwab received a request, signed by Kahn and Epstein, to wire 11,150,000 euros, $12,708,324, to Marc Leon in Marrakech, a partner in a firm offering luxury property in Morocco and France, at an account at Bank Julius Baer in Zurich.34 Kahn telephoned the next day to ask whether the wire could be terminated, saying that terms “we were told we had on uh an agreement, were uh, not, were reneged on this morning”; the wire was retracted at a loss of $113,527.80 on the currency conversion and the funds were redeposited on July 10.3435 A second request, for $14,950,000 to the same recipient, was made on July 4; Epstein was arrested on July 8; Kahn emailed on July 9 asking to “please cancel this wire,” and confirmed the cancellation by telephone on July 10.35 The report adds that the three Schwab accounts were funded from Deutsche Bank Trust and FirstBank accounts and by transfers from other brokerages, that Southern Trust’s account received a $2,000,000 wire from a like-registered account, and that a Southern Financial account there received a $2,000,000 wire and two cheques recorded as promissory interest payments, one from Coatue Enterprises LLC and one drawn on an account of Darren Indyke.36

The report describes the company as “registered in the United States (U.S.) Virgin Islands, license number 1-21-772-1L, as a business and management consulting firm, and was established in December 2018”. That is a formation date that conflicts with the November 18, 2011 incorporation recorded in the company’s Deutsche Bank file and pleaded in the Virgin Islands complaint.1113

Money in and out

Payments from Leon Black and others

An email of August 13, 2019 transmitting charts drawn from Deutsche Bank’s document production, under the heading “Exhibit A: Leon Black / Rothschild Group Transactions,” lists fifteen incoming payments to Southern Trust Company between October 15, 2013 and April 25, 2017 from Leon Black, from Black Family Partners, LP and from Narrow Holdings LLC, ranging from $2,000,000 to $20,000,000, together with two December 2015 payments to the company of $10,000,000 from Edmond de Rothschild (Suisse) SA in Geneva and $14,999,980 from Benjamin Edmond de Rothschild.37 The chart gives dates, payers and amounts and states no purpose for any of them.37 Two letter agreements from Edmond de Rothschild (Suisse) S.A. to Darren K. Indyke as Vice President of Southern Trust, dated October 5 and October 23, 2015, each provide that the bank “shall pay STC $10,000,000” (the earlier by not later than November 15, 2015, the later by not later than November 30, 2015) for work each instrument defines only as what the parties agree “from time to time”. The October 5 copy is signed for the bank by its chief executive and chief financial officer; the October 23 copy carries no signature at all, and the line for Southern Trust is blank on both. Nothing cited here states that the December 17, 2015 payment was made under either agreement, or which version was operative, and this page does not infer it. See Edmond de Rothschild (Suisse) S.A.38 The review of Black’s dealings with Epstein commissioned by Apollo Global Management’s board and prepared by Dechert LLP, dated January 22, 2021, puts the payments “for work performed over the period 2012 through 2017” at $158 million and states that the firm “has seen no evidence suggesting that Black ever compensated Epstein for any service other than Epstein’s legitimate advice on trust and estate planning, tax issues, issues relating to artwork, Black’s airplane, Black’s yacht, and other similar matters, philanthropic issues, and the operation of the Family Office.”39 The Senate Finance Committee, which opened its own inquiry into the payments in 2022, wrote to Black in July 2023 that his answers had failed to substantiate how the payments were calculated.40

In April 2017 Deutsche Bank asked Kahn about a $22,500,000 wire received on March 31 from BV70 LLC, telling him it had been “flagged by our auditors at random.”41 Kahn answered that “Entity BV70 LLC is owned by Leon Black, who is a client of Southern Trust Company,” that BV70 owned Black’s yacht, that the “purpose of wire was fees” and that “another 8-10mm is expected.”42 The wire itself went to an account of Plan D, LLC, another Epstein company, not to Southern Trust or Southern Financial: the bank’s compliance inquiry is captioned to the Plan D account, and its transaction chart records the March 31 and a further April 17, 2017 payment from BV70 as running to Plan D.4337 The Dechert report describes those two 2017 transfers not as fees but as loans: “Separate from the payments made to Epstein or his entities between 2013 and 2017 for services rendered, Black made two loans to Epstein, for $22.5 million and $8 million, respectively, in early 2017,” structured as being made by BV70 to Plan D, payable on demand and made in connection with an art transaction.44

Hedge fund subscriptions

Deutsche Bank’s presentation to the U.S. Attorney’s Office summarises the hedge fund investments made from the relationship’s accounts:

FundWiresTotalEpstein account
Boothbay Absolute Strategies Fund LP5$28,250,000Southern Financial LLC
Boothbay Multi Strategy Fund LP1$10,000,000Southern Financial LLC
Honeycomb Partners LP6$63,000,000Southern Trust Company Inc.
Honeycomb Ventures IV LP1$10,000,000The 2017 Caterpillar Trust
Valar Global Fund II LP5$6,300,000Southern Trust Company Inc.
Valar Global Fund III LP11$22,500,000Southern Trust Company Inc.

45

Individual wires appear in the bank’s transaction charts, among them subscriptions to Valar Global Fund II from Southern Trust and to Boothbay from Southern Financial in 2014 and 2015.46 A wire confirmation of May 31, 2016 for $20,000,000 from a Southern Trust money market account to Honeycomb Partners LP at Northern Trust records the instruction as FAILED, the reason given being that “Cumulative Wire transactions exceeded the company’s daily limit”; the balance shown at the time of the request was $80,875,213.15.47 An April 2019 Deutsche Bank statement for the company’s business checking account shows a $1,500,000 outgoing wire to Valar Global Fund III LP at Silicon Valley Bank on April 17, alongside $2,000,000 sent to Charles Schwab and $5,000,000 sent in two payments to National Financial Services.48

Payments recorded by Deutsche Bank as notable

Exhibit P of the bank’s September 2019 presentation, “Notable Payments to High Profile Individuals,” lists four recipients paid from the two companies’ accounts: $200,000 to Cecile de Jongh on December 29, 2015 from Southern Trust; $250,000 to Terje Rød-Larsen on December 21, 2015 from Southern Trust, the bank noting Epstein “appears to have been a significant benefactor” of the International Peace Institute; $1,196 and $37 to L H Summers Economic Consulting LLC on November 7 and November 24, 2014 from Southern Trust, the wire details reading “Travel Expenses”; and four payments to Joichi Ito from Southern Financial between July 2014 and April 2015, of $250,000, $500,001, $250,000 and $1,000,000, the last to an Ito-led investment vehicle.4950 Against de Jongh’s name the bank recorded that she “is the former First Lady of the U.S. Virgin Islands” and that “[t]here have been public reports that she worked as an ‘Office Manager’ for Epstein’s companies during her husband’s tenure as Governor.”49 No response from any of these recipients about these payments is recorded on this page.

Exhibit N of the same presentation, a timeline of payments to or on behalf of alleged co-conspirators, lists five payments made from a Southern Financial account: $100,000 to Lesley Groff on February 1, 2016, $100,000 to Groff on January 3, 2017, a further $100,000 on December 19, 2017 recorded to Groff and a second named individual, and $50,000 and $150,000 to the pilot Lawrence Visoski on March 28, 2017 and January 12, 2018, both marked “Promissory note.”51 The heading and the classification are Deutsche Bank’s; a footnote to the exhibit records that Groff was one of the four co-conspirators given immunity under the 2008 non-prosecution agreement.51 No response from any of them is recorded on this page.

Payroll and other payments, 2018

A schedule setting out the “[p]urpose/reason for each payment” lists eleven Epstein-entity payments, nine of them dated in 2018 and eight of them drawn on Southern Trust accounts:52

DateAmountPayeePurpose as stated
April 26, 2018$37,000American YachtOffice rent, withheld pending repairs — “5 month of back rent”
May 3, 2018$38,000American YachtOffice rent, withheld pending repairs — “5 month of back rent”
September 4, 2018$50,000Citizens for Better GovernmentPolitical contribution
October 29, 2018$10,000Democratic CongressionalPolitical contribution

The same schedule records the company’s payroll on December 20 and 21, 2018: four year-end bonuses totalling $33,327.30, of which $11,308.50 went to Jeanne Brennan Wiebracht and $7,167.80 to Cecile R. de Jongh; the remaining two bonuses were paid to an accountant for the company and an IT manager, who are not named here.52 De Jongh was still on the company’s payroll almost four years after her husband’s term as Governor of the U.S. Virgin Islands ended in January 2015.5249

Economic Development Commission benefits

Six letters written by the Commission and its parent Authority about this application, running from October 2012 to February 2014, are cited in this section. All are addressed to Erika Kellerhals, Esq., counsel for the company. Four of the six name her firm: Kellerhals Ferguson, LLP in October 201253 and January 2013,54 and Kellerhals Ferguson Kroblin PLLC in January55 and February 2014.56 Of the other two, one addresses her at “Attorneys at Law”57 and one gives no firm name at all.58 Each is evidence of what its author told counsel on the date it bears, and not of the truth of what the applicant had told the Commission.

On October 17, 2012 Margarita Greenidge-Benjamin, Director of Applications at the Economic Development Commission,55 wrote that the Commission had “received an application on behalf of Southern Trust Company, Inc. for consideration of Economic Development tax Benefits” on September 21, 2012, and that nine items were “missing and must be submitted in order to complete the application”: a “Release Authorization and Truth Statement for Mr. Jeffrey E. Epstein,” a bank reference letter, an income tax return, a Form 8821, a training budget, revised five-year projections “to include training, charitable contribution and notes to explain assumptions,” an answer on whether the employee benefit plan would include life insurance, a breakdown of local against non-local purchases, and a commitment to comply with Section 5 of Act No. 7301.53 On November 5 she wrote again: the application “was reviewed and accepted as completed on October 25, 2012” and would be placed on the public hearing agenda for Thursday, November 15, 2012, in the Virgin Islands Port Authority’s conference room at the Cyril E. King Airport. “Please come prepared to give testimony and answer questions pertaining to the application.”57

Six days after that hearing the Commission asked for more. Over her signature on November 21, 2012, Greenidge-Benjamin wrote that the Commission, “following its Public Hearing on November 15, 2012 is requesting supplemental information in order to assist in the processing of the submitted application for EDC Board consideration,” and put two numbered questions to counsel: “Provide notes to the Applicant’s 5 year projection particularly for the explanation of its income generation,” and “Did Southern Trust Company, Inc. request a residential waiver? If yes, please explain”. A response by November 27, 2012 was “appreciated” so that the Commission could “complete this application and present it to the EDC Governing Board for a decision.” Jennifer Nugent-Hill, the Authority’s Assistant Chief Executive Officer, and an application analyst were copied.58

Notifying counsel on January 31, 2013, Nugent-Hill wrote that the Governing Board of the Commission had considered the application “during its Decision Meeting on January 23, 2013”, and that the “grant of benefits”, as described in Item A of Attachment No. 1, “is being recommended to the Governor.”54 Item A sets a 90 percent exemption from income taxes, 100 percent exemptions from real property, gross receipts and excise taxes, customs duties at “1% Not Applicable” and interest and dividends taxes at “Exemption and partial exemption as provided in 713d,” for ten years, with the business operation located on St. Thomas. Item B, headed “The Type of Business Granted Benefits,” describes something narrower than consulting: “The Applicant will conduct the operation of a Category IIA designated service business providing extensive DNA database and develops a data-mining platform for the database to be available through the Internet. All of the Applicant’s clients will be located outside the U.S. Virgin Islands.”59

The conditions were specific. The company was to employ five full-time employees within one year of the date the Chairman signed its certificate and five more by the end of its sixth year of operation; it was “granted a 50% resident employment waiver for the first five (5) years of operation” and was to contribute $2,500 a year to the Territorial Scholarship Fund “for each non-resident that causes it not to meet the 80% requirement”; and it was to “invest at least Four Hundred Thousand U.S. Dollars ($400,000) in the benefited business upon commencement of benefits and completing one (1) year thereafter.”54 Item C added thirteen special conditions, among them a minimum charitable contribution of $50,000 a year.59 Counsel was asked to sign an accept or a decline line and return the letter by February 15, 2013; both lines are blank on the copy in the release.60 What the Government alleges the company’s employment and income actually were in the years that followed is set out below.

The certificate followed a year later. Percival E. Clouden, the Authority’s Chief Executive Officer, wrote on January 17, 2014 enclosing “the Economic Development Commission Certificate for Southern Trust Company, Inc.” and asking that “both originals” be endorsed “by the party empowered to sign on behalf of the Company.” The copy in the release carries a received stamp of the Economic Development Authority’s St. Thomas office dated JAN 21 2014, and its distribution list names four Authority and Commission officers and “Jeffrey Epstein, President.”55 The certificate repeats Item B’s description of the business and adds two particulars the Board’s attachment does not carry: “The Beneficiary’s services include the development of financial and biomedical informatics,” and “Information will be kept on servers located in the U.S. Virgin Islands.”61 Its appendices set the income exemption at 90 percent and the gross receipts and excise exemptions at 100 percent, commencing February 1, 2013 and terminating January 31, 2023;62 grant dividend and interest withholding exemptions on the same dates and list Epstein as the sole member, owning 100 percent;63 record a 100 percent real property exemption whose commencement and termination dates are both “Not Applicable”;64 and set a one percent customs duty rate, also “Not Applicable.”65 The execution page of the copy in the release carries no entries: the date line and the signature line above the printed name “Albert Bryan, Jr., Chairman” over “Economic Development Commission”, the four witness lines, and the company’s “Accepted by” and “Name and Title” lines are all blank.66

The last of the six letters records a petition from the company for more time to meet the capital-investment condition. Writing on February 20, 2014, Nugent-Hill gave “formal notification relative to the actions taken by the Governing Board” that it had “voted at its January 24, 2014 decision meeting to approve the petition by Southern Trust Company, Inc. in accordance with EDC Rules and Regulations §§ 708-203 and 718-4(c)(2), to grant an extension of time for Southern Trust Company, Inc. to meet its capital investment requirement by February 1, 2015.” Counsel was again asked to sign and return by March 6, 2014; the accept and decline lines are blank on this copy, which is stamped COPY.56

The Government of the Virgin Islands’ amended complaint tells the same sequence as a party’s allegation. It pleads that the company applied to the Economic Development Commission in October 2012; that at a public hearing on November 15, 2012 Epstein and his attorney described it as providing “cutting edge consulting services” in “biomedical and financial informatics”; and that the commission granted a ten-year package running from February 1, 2013 to January 31, 2023, with a 90 percent exemption from income taxes and full exemptions from gross receipts, excise and withholding taxes.67 The hearing testimony is the pleading’s account and not the correspondence’s. Between them the six Commission letters record the hearing’s date, place and purpose. The notice of November 5, 2012 gives all three; the supplemental request of November 21 and the certificate refer back to it by date; the completeness letter of October 17 mentions a public hearing without giving its date or place; and the two Board letters do not mention it at all. None of the twenty sheets that make up the six reports what was said at the hearing or who said it. The machine text of all twenty sheets was searched for hearing, testimony, testify, orally, stated, said, spoke and represent, and every sheet that returned a hit was then read at the image. What the letters establish about Kellerhals is that she was the applicant’s correspondent with the Commission.

On three particulars the Commission’s file and the pleading do not line up. The Commission’s letters date receipt of the application to September 21, 2012 and its acceptance as complete to October 25, 2012, where the complaint pleads that the company applied in October 2012.535767 The complaint describes the grant as the Commission’s act; the Board’s letter says the grant of benefits “is being recommended to the Governor,”54 and the certificate recites that the Commission enters into it “with the prior approval of the Governor of the Virgin Islands of the United States.”66 And the certificate carries two heads of benefit the complaint’s list does not: a 100 percent real property exemption,64 and a one percent customs duty rate,65 each with its commencement and termination dates recorded as “Not Applicable.”

The fourth divergence is the one the action turns on, and the pleading puts it as an inference rather than as a finding. Its ¶114 opens: “Based upon these facts, it is clear that Southern Trust Company did not perform the ‘informatics’ business represented to the EDC and could not have generated the business income attributable to that business.”15 The facts referred to are the employment and income figures pleaded in the paragraphs before it, which are set out in the next section of this page. What the Commission’s own documents settle is the prior question of which business the benefits were granted for, and the answer is not informatics at large: a “Category IIA designated service business providing extensive DNA database” and a “data-mining platform for the database to be available through the Internet,”5961 with financial and biomedical informatics named among the services included within that business and the information to be kept “on servers located in the U.S. Virgin Islands.”61 Whether the company then performed that business is not recorded on any of the twenty sheets, which run to February 2014 and record the application, the grant and its conditions; the complaint’s allegation that it did not rests on the employment and income figures, and not on how the certificate described the work.

Compliance was still open six years later. Forwarding the correspondence to Epstein on October 1, 2018, de Jongh passed on a Virgin Islands Economic Development Authority compliance officer’s September 21 letter, which listed items still required “to complete Southern Trust Company’s 2013 to 2016 compliance review,” gave notice of a site visit on October 31, 2018 and proposed an outreach visit by the authority’s new chief executive.68

The Virgin Islands action

Southern Trust Company was a named defendant in the Government of the Virgin Islands’ First Amended Complaint against Epstein’s estate, which alleges violations of the territory’s Criminally Influenced and Corrupt Organizations Act.369 The complaint states that Epstein was the company’s president and director from 2011 until at least 2018, with Kahn and Indyke as treasurer/director and secretary/director, that Epstein was its sole owner, and that it was a tenant at American Yacht Harbor in Red Hook, in which Epstein was a “passive investor.”3 It pleads that the company reported assets of $198.5 million by the end of 2013 and $391.3 million four years later, that it employed thirteen people between 2013 and 2019 of whom eleven were in administrative or support roles, that it reported aggregate income of $656 million over the period, and that it received tax exemptions totalling $73.6 million between 2013 and 2017.37071

From those figures the complaint draws its allegation: “it is clear that Southern Trust Company did not perform the ‘informatics’ business represented to the EDC and could not have generated the business income attributable to that business,” and that the company “existed to secure tax benefits for Epstein, to employ individuals associated with the Epstein Enterprise, and to provide a source of income to support his criminal activities and properties in the Virgin Islands.”15 Those are the Government’s allegations, pleaded in part on information and belief. The action is brought against Epstein’s estate, and no answer from him to them exists.

Financial Trust Company; Deutsche Bank; JPMorgan Chase; Gratitude America, Ltd.; HBRK Associates; LSJE, LLC; JEGE LLC; J. Epstein & Co.; Cecile de Jongh; Darren Indyke; Richard Kahn; Harry Beller; Jeanne Brennan-Wiebracht; Leon Black; Little Saint James; Epstein’s sex-offender registration in the U.S. Virgin Islands; Butterfly Trust; Edmond de Rothschild (Suisse) S.A..

Footnotes

  1. Deutsche Bank know-your-customer print, legal entity sheet for Southern Trust Company, Inc. (print page 17 of 22): country and date of incorporation, address, sole shareholder and account signatories. https://epstein-data.com/EFTA01356046 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  2. Jeanne Brennan to Deutsche Bank, March 14, 2013, with the account-opening particulars of both companies, forwarded internally on March 15. https://epstein-data.com/EFTA01463133 p.1. ↩ ↩2 ↩3 ↩4 ↩5

  3. Government of the Virgin Islands, First Amended Complaint against the Estate of Jeffrey Epstein, ¶37. https://epstein-data.com/EFTA00018778 pp.8–9. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  4. Internal organisation chart, Southern Trust Company, Inc. administration office and HBRK. https://epstein-data.com/EFTA01304254 p.1. ↩ ↩2 ↩3 ↩4

  5. Deutsche Bank Securities enhanced due diligence memorandum on Southern Financial LLC, December 19, 2014, forwarded January 16, 2015. https://epstein-data.com/EFTA01418996 pp.2–3. ↩ ↩2 ↩3 ↩4 ↩5

  6. Deutsche Bank know-your-customer print, legal entity sheet for Southern Financial LLC (print page 16 of 22). https://epstein-data.com/EFTA01356221 ↩ ↩2 ↩3

  7. Cecile de Jongh to Jeffrey Epstein, March 22, 2013, subject “FTC to STC.” https://epstein-data.com/EFTA01901187 p.1. ↩ ↩2 ↩3 ↩4

  8. FirstBank, San Juan, response to a grand jury subpoena, March 9, 2020. https://epstein-data.com/EFTA00065864 p.3. Other pages of this production are not cited. ↩ ↩2

  9. JPMorgan remittance list by account, March 14, 2013. https://epstein-data.com/EFTA01583431 p.1. ↩ ↩2

  10. The same presentation, Exhibit B, nature and purpose of active and capitalised accounts. https://epstein-data.com/EFTA01681865 p.4. ↩ ↩2

  11. Suspicious activity report filed by The Charles Schwab Corporation, July 13, 2019, narrative. https://epstein-data.com/EFTA01656452 p.6. ↩ ↩2 ↩3 ↩4

  12. Deutsche Bank know-your-customer print, continuation of the Southern Trust Company sheet (print page 18 of 22): nature of the business, countries of business, number of employees and wealth profile. https://epstein-data.com/EFTA01356007 ↩ ↩2 ↩3

  13. JPMorgan consolidated statement for Financial Trust Company, Inc., period March 1–31, 2013, “Securities Transferred Out.” https://epstein-data.com/EFTA01494013 p.1. ↩ ↩2

  14. Deutsche Bank presentation to the U.S. Attorney’s Office for the Southern District of New York, September 12, 2019, Exhibit A. https://epstein-data.com/EFTA01681865 p.2. ↩

  15. The same complaint, ¶114. https://epstein-data.com/EFTA00018778 p.24. ↩ ↩2 ↩3

  16. Deutsche Bank to Jeanne Brennan, June 12, 2013, listing outstanding account-opening items. https://epstein-data.com/EFTA01463339 p.2. ↩

  17. Deutsche Bank know-your-customer print, wealth profile continuing the Southern Financial LLC sheet, at the head of print page 17 of 22. https://epstein-data.com/EFTA01356046 ↩

  18. The same thread with Epstein’s reply of March 22, 2013 and de Jongh’s follow-up of March 25 and 26. https://epstein-data.com/EFTA01899598 p.2. ↩

  19. JPMorgan private bank internal email chain, April 9–24, 2013, on the Financial Trust account overdraft. https://epstein-data.com/EFTA01589653 p.1. ↩

  20. The same report, ¶7. https://epstein-data.com/EFTA02730996 p.4. ↩

  21. JPMorgan private bank internal email chain, March 22, 2013, on a business credit card for the company. https://epstein-data.com/EFTA01583355 p.1. ↩

  22. JPMorgan private bank internal email chain, April 2–4, 2013, seeking executive endorsement for the card. https://epstein-data.com/EFTA01583354 p.1. ↩

  23. JPMorgan internal email, September 19–20, 2013, dividing the two companies’ securities between the bank and Deutsche Bank. https://epstein-data.com/EFTA01583295 p.1. ↩

  24. Letter on Southern Financial, LLC letterhead dated September 30, 2013 authorising the transfer of its checking account to Deutsche Bank, with the bank’s call-back block. https://epstein-data.com/EFTA01578681 p.1. ↩

  25. JPMorgan private bank email, October 1, 2013, summarising six cash transfer requests. https://epstein-data.com/EFTA01578684 p.1. ↩

  26. JPMorgan internal email, October 16, 2013, on outstanding securities for Southern Trust. https://epstein-data.com/EFTA01583339 p.1. ↩

  27. “Epstein exit of accounts”: JPMorgan call-back note recording wire instructions and internal email of February 18, 2014 confirming the close-out. https://epstein-data.com/EFTA01583338 p.1. ↩ ↩2

  28. Draft schedule to a 2002 ISDA Master Agreement between Deutsche Bank AG and Southern Trust Company, Inc. https://epstein-data.com/EFTA01449992 p.1. ↩

  29. Termination agreement dated as of December 7, 2016 between Deutsche Bank AG and Southern Financial LLC, with its signature page. https://epstein-data.com/EFTA01424302 pp.1, 3. ↩

  30. Deutsche Bank internal recall notice, July 30, 2018, carrying the subject line of the message on the 2018 periodic review of high-risk accounts under the “SOUTHERN FINANCIAL RELATIONSHIP.” https://epstein-data.com/EFTA01421805 p.1. ↩

  31. Deutsche Bank know-your-customer correspondence, August–September 2018, listing pending items for the Southern Financial and LSJE accounts. https://epstein-data.com/EFTA01424823 pp.2, 4. ↩

  32. Deutsche Bank internal email chain, June 10–11, 2019. https://epstein-data.com/EFTA01423566 p.2. ↩

  33. The same presentation, Exhibit E, timeline of the Butterfly Trust, final entry. https://epstein-data.com/EFTA01681865 p.14. ↩

  34. The same report, narrative continued. https://epstein-data.com/EFTA01656452 p.7. ↩ ↩2 ↩3

  35. The same report, narrative continued. https://epstein-data.com/EFTA01656452 p.8. ↩ ↩2

  36. The same report, closing narrative. https://epstein-data.com/EFTA01656452 p.9. ↩

  37. Email of August 13, 2019 transmitting transaction charts drawn from Deutsche Bank’s document production, Exhibit A; three of the six recipients’ names are redacted, as are all six of their addresses. https://epstein-data.com/EFTA00080250 pp.1–2. ↩ ↩2 ↩3

  38. Letter of Agreement dated October 5, 2015 from Edmond de Rothschild (Suisse) S.A. to “Mr. Darren K. Indyke, Vice President, Southern Trust Company, Inc.,” first sheet (the recital, ¶1 The Work and ¶2 with the November 15, 2015 payment date) and fifth sheet (the signature page, signed in blue ink for the bank, the Southern Trust line an unmarked rule): https://epstein-data.com/EFTA01110892 pp.1, 5. The later Letter of Agreement dated October 23, 2015 to the same addressee, first sheet and fifth sheet (all three “By:” lines unmarked rules, carrying neither ink nor a redaction bar): https://epstein-data.com/EFTA00648735 pp.1, 5. All four sheets rendered locally and read at the image, 2026-09-10T00:08Z and 2026-09-10T00:16Z. ↩

  39. Dechert LLP to the Apollo Conflicts Committee, January 22, 2021, ¶5. https://epstein-data.com/EFTA02730996 p.4. ↩

  40. Senate Finance Committee to Leon D. Black, July 24, 2023. https://epstein-data.com/EFTA02731023 pp.1-2. ↩

  41. Deutsche Bank to Richard Kahn, April 11, 2017, inquiry about the incoming wire. https://epstein-data.com/EFTA01419529 p.4. ↩

  42. Kahn’s replies of April 11 and 12, 2017. https://epstein-data.com/EFTA01419529 pp.1, 3. ↩

  43. Deutsche Bank anti-money-laundering compliance inquiry and answers, April 11–12, 2017, captioned to the Plan D, LLC account. https://epstein-data.com/EFTA01423373 p.1. ↩

  44. The same report, section V. https://epstein-data.com/EFTA02730996 p.17. ↩

  45. The same presentation, Exhibit K, hedge fund investments. https://epstein-data.com/EFTA01681865 p.25. ↩

  46. The same email, Exhibit B, transactions involving hedge and investment funds. https://epstein-data.com/EFTA00080250 p.2. ↩

  47. Deutsche Bank wire confirmation, May 31, 2016, “STC to Honeycomb Partners.” https://epstein-data.com/EFTA01376049 p.1. ↩

  48. Deutsche Bank business checking statement for Southern Trust Company, Inc., April 1–30, 2019. https://epstein-data.com/EFTA01288388 pp.1–2. ↩

  49. The same presentation, Exhibit P, first page. https://epstein-data.com/EFTA01681865 p.37. ↩ ↩2 ↩3

  50. The same presentation, Exhibit P, continued. https://epstein-data.com/EFTA01681865 pp.38–39. ↩

  51. The same presentation, Exhibit N. https://epstein-data.com/EFTA01681865 p.30. ↩ ↩2

  52. Schedule of Epstein-entity payments with the stated purpose of each, 2018. https://epstein-data.com/EFTA00802367 p.1. ↩ ↩2 ↩3

  53. Margarita A. Greenidge-Benjamin, Director, Applications, on Economic Development Commission letterhead, to Erika Kellerhals, Esq., October 17, 2012, listing the items missing from the application. https://epstein-data.com/EFTA01100239 p.1. ↩ ↩2 ↩3

  54. Jennifer Nugent-Hill, Assistant Chief Executive Officer, to Kellerhals, January 31, 2013, “Recommendation for Economic Development Benefits,” first sheet. https://epstein-data.com/EFTA01110746 p.1. ↩ ↩2 ↩3 ↩4

  55. Percival E. Clouden, Chief Executive Officer, Virgin Islands Economic Development Authority, to Kellerhals, January 17, 2014, enclosing the certificate. https://epstein-data.com/EFTA00800312 p.1. ↩ ↩2 ↩3

  56. Nugent-Hill to Kellerhals, February 20, 2014, notifying the Governing Board’s vote of January 24, 2014 on the capital investment requirement. https://epstein-data.com/EFTA01100317 p.1. ↩ ↩2

  57. Greenidge-Benjamin to Kellerhals, November 5, 2012, recording acceptance of the application as completed and setting the public hearing. https://epstein-data.com/EFTA00306022 p.1. ↩ ↩2 ↩3

  58. Greenidge-Benjamin to Kellerhals, November 21, 2012, requesting supplemental information after the public hearing. https://epstein-data.com/EFTA00618053 p.1. Read at the image at 300 dpi: a handwritten signature crosses the printed name, and the sheet’s redaction is matched by a gap in the extraction, the two agreeing. Telephone numbers on this page are not reproduced here. ↩ ↩2

  59. The same letter, Attachment No. 1, Notice of Recommendation for Economic Development Benefits: Items A and B and the first two special conditions on the third sheet, the remaining eleven special conditions and Item D on the fourth and fifth. https://epstein-data.com/EFTA01110746 pp.3–5. ↩ ↩2 ↩3

  60. The same letter, second sheet, carrying the signature and the accept and decline lines. https://epstein-data.com/EFTA01110746 p.2. ↩

  61. Economic Development Commission Certificate for Southern Trust Company, Inc., enclosed with that letter, on the second sheet (the certificate’s own page 1 of 10). https://epstein-data.com/EFTA00800312 p.2. ↩ ↩2 ↩3

  62. The same certificate, Appendix A, on the eighth sheet (its own page 7 of 10). https://epstein-data.com/EFTA00800312 p.8. Telephone numbers on this page are not reproduced here. ↩

  63. The same certificate, Appendix A1, on the ninth sheet (its own page 8 of 10). https://epstein-data.com/EFTA00800312 p.9. ↩

  64. The same certificate, Appendix B, on the tenth sheet (its own page 9 of 10). https://epstein-data.com/EFTA00800312 p.10. ↩ ↩2

  65. The same certificate, Appendix C, on the eleventh sheet (its own page 10 of 10). https://epstein-data.com/EFTA00800312 p.11. ↩ ↩2

  66. The same certificate, on the seventh sheet (its own page 6 of 10): the recital of the Governor’s prior approval and the execution block. https://epstein-data.com/EFTA00800312 p.7. ↩ ↩2

  67. The same complaint, ¶¶104–106. https://epstein-data.com/EFTA00018778 p.22. ↩ ↩2

  68. Cecile de Jongh to Jeffrey Epstein, October 1, 2018, forwarding a Virgin Islands Economic Development Authority compliance letter of September 21, 2018. https://epstein-data.com/EFTA01021278 pp.1–2. ↩

  69. The same complaint, Count One. https://epstein-data.com/EFTA00018778 p.24. ↩

  70. The same complaint, ¶107. https://epstein-data.com/EFTA00018778 p.22. ↩

  71. The same complaint, ¶¶111–113. https://epstein-data.com/EFTA00018778 p.23. ↩

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