Epstein Data Wiki

JPMorgan's Due Diligence on Epstein and Maxwell

Properties1
tagstopic, jpmorgan-chase, private-bank, due-diligence, know-your-customer, ghislaine-maxwell

43 min read

The unitJPMorgan Chase’s Global Security & Investigations group, named in full on the reports it produced and abbreviated on the forms as GS&I, GSI, GCS and GDDO1234
The instrumentsA banker-completed “USCG Due Diligence Report” (DDR), cited here in its Corporation, Individual and Fiduciary variants, with a Security Services section completed by the investigations group; a “Confidential Due Diligence Report” written by that group; and, from about 2012, a “KYC Summary” ticket5167
Subjects researchedJeffrey Epstein, Ghislaine Maxwell, Robert Maxwell, and the entities 116 East 65th St., LLC, MAX Foundation, Pot and Kettle, Ellmax and Terra Mar Project Inc8911011
Investigations requested byMary Casey (23 January 2009), Mary C Casey (30 November 2009), Paul Morris (24 and 29 August 2011, 30 April 2012), Kirsten Sichler (12 February 2013)89110112
Decision recorded on keeping EpsteinThe February 2009 DDR for 116 East 65th St., LLC records: “Jes Staley conferred with Steven Cutler and the decision was made to keep him as a PB client but only for banking and custody”12
Decision recorded on exiting MaxwellThe 2014 know-your-customer ticket records: “In a 12/6/13 RRC mtg, the decision was made to exit Maxwell”, and “CLIENT EXITED THE BANK ON REQUEST OF RISK COMMITTEE AND THE LAST ACCOUNTS CLOSED JUNE 8, 2014”13
ProductionProduced to the Southern District of New York under a request for confidential treatment; every page is footed “Confidential Treatment Requested by JPMorgan Chase”1415
The bank’s positionJPMorgan denied liability and wrongdoing in the trafficking actions brought against it and said publicly that any association with Epstein “was a mistake and we regret it”1617

Between 2003 and 2014 JPMorgan Chase’s Private Bank ran a series of background investigations on Jeffrey Epstein, on Ghislaine Maxwell and on companies and foundations connected to them, and recorded on the same forms what its bankers decided to do about what came back.51213 The file was produced to the Southern District of New York under a request for confidential treatment.14 It contains the investigations group’s reports, the banker-completed due diligence reports that commissioned them, and the later know-your-customer tickets that closed the relationship. Asked by the House Committee on Oversight and Government Reform what a due diligence report is, Jes Staley answered that it is “a report that the bank has studied a certain topic and it has done its due diligence, whether it’s know-your-client, whether it’s AML, anti-money-laundering.” Asked what action would trigger the creation of one, he said he did not know specifically; asked next what would trigger an update to one, he said opening an account or extending a loan would.18

Nothing on this page is a finding of wrongdoing by the bank or by any of its employees. The forms are records of what the institution asked, what it was told, and what it then decided.

Several of these instruments were produced more than once in the release, some as whole documents and some as runs of separately numbered single pages. Where that happens this page cites one copy of each instrument and does not treat a second copy as a second report.

The decision-maker record

The Private Bank filed its Epstein-related due diligence reports under a single decision-maker record in Jeffrey Epstein’s name, and each form reproduces the list of every other report attached to that record.5 The list on the MAX Foundation form names, among others, 116 East 65th St., LLC; Darren K. Indyke PLLC; EMMCAC, LLC; “Epstein, Jeffrey”; Financial Trust Company, Inc. twice; Freedom Air International, Inc.; HBRK Associates Inc.; Hyperion Air, Inc.; I-Correct.com LLC; “Indyke, Darren K”; Jege, Inc.; New York Strategy Group, LLC; Plan D, Inc.; three 2007 Epstein insurance trusts; The C.O.U.Q. Foundation, Inc.; and The Haze Trust.5 The dates printed in its “Security Services Search Date” column run from 1999 to 2011.5

The table cannot be read as a list of pairs. Read at the page image, two of its name rows are blacked out, several names wrap onto a second line while the date column does not, and the two columns therefore do not align row for row. It shows that the reports existed and roughly when they were run; it does not establish which date belongs to which report, and this page does not count its entries.5

2003 to 2005: the checks that preceded the Maxwell account

The earliest step recorded in the file is a Security Services check on Ghislaine Maxwell begun by Marisol X Torres-Soler on 11 March 2003, with the search type marked “Full”.19 The completed form records that Maxwell “was fully researched in Florida and New York” and that “Robert Maxwell was searched through Derogatory News and Sanction records only”, adding: “PLEASE NOTE: Search parameters were adjusted due to the high volume of records on Robert Maxwell.”19 The banker’s summary on the same form records that Maxwell “is now in the process of opening up a new checking account”, answers “No” to “Is this entity a high profile client?”, and answers “No” to whether an approval had been obtained from senior management; the Client Advisor Approval and Senior Manager Approval blocks both read “(Not Yet Approved)”.20

The individual due diligence report that took Maxwell on as a client of the Private Bank was completed two years later. Its temporary waiver block records a waiver requested by Vanessa A Williams on 14 March 2005 and approved by David M Tarrio the same day, with the reason given as “Security Services is still performing the client background check”.21 The banker’s own entries record that “Ms. Maxwell was referred to us by Jeffrey Epstein”, answer “No” to whether the principal had been met, and explain: “We have had numerous meetings with Jeffrey Epstein but not yet with Ghislaine. Jes Staley has met Ghislaine.”22 This page and the live entry on Jes Staley both describe this instrument as a report on a prospective client, and its own introduction fields point the same way; but the same report’s Individual Checks comment calls her “an existing client,” its summary of findings states “We opened a checking account for her in 2003,” and its approval block records the banker as approving “the acceptance of Ghislaine Maxwell … as a Client.” The file carries both descriptions and this page does not choose between them.2321

What the 2005 report says it did not research

The Security Services section of that form is a four-column table headed “Search Type”, “Is Further Review by Banker Required?”, “Security Service Details:” and “Banker Response:”.24 Read at the page image, the “No” against each row is the answer to whether the banker had to review the item further, not a search result; the result sits in the “Security Service Details” column.2415 In that column, six categories read “Not researched.”: Corporate Records, Other Database Searches (RDC/CDC/MIS), State Court Searches, Federal Court Searches, Personal Particulars and Regulatory Sanctions.2415 Company Information reads “No records were found.” Publications and OFAC point to an attached document. The internal database search is the one row marked “Yes” for further banker review, and its own text explains the six unrun categories: “Reference the Due Diligence Report titled ‘Ghislaine Maxwell’ (118503B) for a FULL report on Ghislaine Maxwell and a MEDIA report on Robert Maxwell. No research was conducted on Robert Maxwell under this particular DDR. Ghislaine Maxwell was updated for international news and company records. Please note derogatory information was found under this DDR.”24 On its own account, this report is an update against an earlier full report rather than a fresh full investigation.

The distinction matters because the same form family uses a different phrase elsewhere. On the 2009 reports the details column reads “No additional research necessary”, which reports a judgement that the search had been covered before, consistent with this report’s own framing of itself as an update rather than a fresh full search; “Not researched” reports that the search was not run.1225

The Security Services section carries the printed name “Witold X Cyrek” against a field labelled “Signed by:” and the date 31 March 2005; there is no manuscript signature on the page.15

The banker’s written answer

The banker’s response, which runs down the right-hand column of the same table and across two produced pages, reads in full: “Please see DDR from 2003 for responses to each of the articles. Ghislaine Maxwell is a very close friend of Jeffrey Epstein who is an existing client and who has recommended us to her. Jes Staley also has met with her and has recommended we open an account for her. In reading the press articles, we have no reason to believe that she had any direct influence on or participation in the situations in which her brothers were involved. She is a high profile client given her family background and media coverage surrounding her father’s death.”2415

The “press articles” the response refers to are itemised in the Publications row of the same table, which records that the information “was originally reported under the Ghislaine Maxwell DDR # 1185/03” and lists newspaper articles about the Serious Fraud Office investigation into Robert Maxwell, the criminal fraud charges brought against Kevin and Ian Maxwell, an article of 9 August 1996 reporting Ghislaine Maxwell’s arrest on driving charges, and an article of 1 December 2000 which the report quotes as stating that “Ghislaine Maxwell’s source of wealth is being classified as something of a mystery.”15 The report attributes each item to a newspaper and gives no other sourcing for any of them.

Under “Individual Checks” the same page records a Morgan Network check dated 31 March 2005 with the comment: “Maxwell was referred by Jeffrey Epstein, a longstanding client of the Private Bank and advisor to Leslie Wexner, also a longstanding client. Jes Staley has met with Ghislaine Maxwell.”15 The report was approved by Mary Rieth as banker and by Tad C Smith as senior manager, both on 11 April 2005.21 The Approval Information block on that page answers “No” to “Public/High Profile Figure”, two pages after the banker’s response called her “a high profile client”.2115 That “No” was not part of the original approval. The file’s whole-document copy of the same report, the only copy that reproduces the form’s audit history, records that Bonnie K Perry, the same Security Services quality reviewer who later signed off the 116 East 65th St. report as “Ok to approve”, performed an “Input/Update High Profile figure set to ‘No’” on 11 March 2006, eleven months after Mary Rieth’s and Tad C Smith’s approvals of 11 April 2005.26

The committee put the banker-response page to Staley in July 2026. Asked about his first interaction with Maxwell he said, “I don’t believe I had interaction with Ghislaine Maxwell”; shown the form, he said, “I don’t” recall meeting her, and, asked whether the bank opened an account for her, “I have learned that they did, yes.”18 Asked whether a recommendation from him carried weight, he answered: “I think there’s a whole process to go to open an account of the Private Bank. That involves compliance departments, legal departments, et cetera. So I think there’s a process that the bank follows. The recommendation would be accounted in that process. But it’s a separate process for opening an account.”18

2004: a report whose subject the production withholds

The file contains a further individual due diligence report, of 2004, whose subject’s name is blacked out throughout the produced copy.2728 Its net-worth field records that the figure came from information “provided by Epstein advisor, Eric Ganey”.27 In the Personal Particulars row the investigations group recorded that the social security number given could not be confirmed as belonging to the applicant, and that a check with the administration listed the number as valid but not yet issued.28 The banker’s summary records that Epstein “has asked us the favor of opening a checking account” for the applicant and that he would guarantee a credit card application.28 The report was signed off in Security Services by Vanessa A Budhu on 8 February 2004 and approved by Mary Rieth as banker and Tad C Smith as senior manager on 9 February 2004.2829

The House committee introduced this report as a minority exhibit in July 2026 and put its contents to Staley, including that no one at the bank had met the applicant, that no government identification had been provided, and that the social security number could not be confirmed. Staley answered: “I think the bank should not be opening an account without doing proper due diligence”, and, asked what proper due diligence would have looked like, “Knowing who the client is, KYC; AML, anti-money-laundering; knowing where the client’s origination of wealth comes from … But if you have an invalid Social Security number, that would be a red flag, et cetera.” He said he had not seen the report and that its contents were not communicated to him.18

2009: two investigations, and the decision to keep Epstein

On 23 January 2009 the investigations group “was requested by Mary Casey to conduct a background investigation” for 116 East 65th St., LLC, a company whose linked decision-maker record is Epstein’s.830 Media research was conducted on the company and on Robert Maxwell. The Robert Maxwell findings box, spanning this page and the one before it, first recites as previously-reported material the Serious Fraud Office investigation, the “source of wealth” line of December 2000, the 1996 driving arrest, the fraud charges against Kevin and Ian Maxwell, and a 2005 story about pledged assets.831 Only after reciting that material does the report turn to a fresh publications search of its own, which it records as: “Publications revealed nothing derogatory. Due to the amount of news stories found, search parameters had to be adjusted.”31 That sentence describes the fresh search, not the box as a whole. It is the second time in the file that a fresh search on Robert Maxwell was narrowed because of the volume of records and then returned nothing derogatory.1931

The banker’s summary of findings on the accompanying form records a decision about Epstein himself. That decision is recorded in more than one place in the file. Two of the bank’s due diligence reports on Epstein life insurance trusts, whose Security Services sections are dated December 2008 and which this page uses further below as completed-form comparisons, record it in their own summaries of findings: one reads “Mr. Epstein was convicted of a felony and is currently serving an 18 month prison sentence. Jes Staley conferred with Stephen Cutler and the decision was made to keep him as a PB client.”32 and the other “Mr. Epstein was convicted of a felony charge and is currently serving an 18 month prison sentence. Jes Staley conferred with Stephen Cutler and the decision was made to keep Mr. Epstein as a client.”33 Neither of them carries the restriction the February 2009 form records, and this page does not establish which record was written first or which the bank treated as its record of the decision. The February 2009 summary reads:

Ghislaine Maxwell is a “high profile figure” for two reasons: i) she is the daughter of the late Robert Maxwell, who died under suspicious circumstances; and ii) she is a close friend of Jeffrey Epstein and his office manages her affairs. On the latter, Mr. Epstein was convicted of a felony and is currently serving a jail term. Jes Staley conferred with Steven Cutler and the decision was made to keep him as a PB client but only for banking and custody. On the former, we have no reason to believe that she had any participation in or influence over the fraudulent activities of which her late father and brothers were once accused in the UK.1230

The Morgan Network entry on the same page, dated 17 February 2009, adds that “Ghislaine Maxwell is an existing client and a DDR was completed on her in 2003. This real estate account was created in the International DDR database in 2006, and this US DDR is to update her information on the US database. Ms. Maxwell is known to Jes Staley.”12 The Approval Information block on this report answers “Yes” to “Public/High Profile Figure” and, against the follow-up asking which description applies, records “Prominent person who is perceived to be controversial”.30 It was approved by Mary C Casey as banker on 17 February 2009, by Marcus Sheridan as senior manager on 24 February, and by Catherine Keating as area head on 26 February, with a quality review by Bonnie K Perry on 25 February recorded as “Ok to approve.”34 Staley told the committee in 2026 that at “the beginning of 2009, 2010” the bank’s general counsel was “Steve Cutler”, that the cash-withdrawal question “did go all the way up to the general counsel of the bank”, and that “it was Steve Cutler’s decision to close him as a client or not.”18

On 30 November 2009 the group “was requested by Mary C Casey to conduct a background investigation” for the MAX Foundation.9 Full research was conducted on the foundation and media research on Maxwell.9 The Maxwell section of that report does not research her afresh. It directs the reader to earlier accounts titled “Ghislaine Noelle Maxwell”, “Forums LLC”, “116 East 65th St LLC” and “Air Ghislaine, Inc”, recites material “previously reported to Mary Reith on 03/17/2003”, and adds one new item: “On September 2009, Ghislaine Maxwell was subpoenaed in a suit against her friend Jeffrey Epstein.”35

Searching the release for the exact phrase “Red Dot (derogatory information)” returns matches in the MAX Foundation form and in eleven other documents; the procedure is not unique to this report, but this is the copy already before the reader. The form defines it: “Red Dot information is any derogatory information identified by Global Security Services which warrants the attention of the banker. The presence of ‘Red Dot’ information does not necessarily mean that an existing relationship will be exited or a potential client relationship not pursued. The banker should document any conversations that have taken place with the client/prospect, if any, with regard of the issue and whether or not this impacts his/her, or management’s decision to continue with or accept the person/entity as a client.”25 On this report the “Has this been identified as a Red Dot DDR?” radio is marked Yes, the “Proceed with or maintain the client relationship” radio is marked Yes, and the banker’s rationale in the adjoining column reads: “As stated previously, the information listed pertains to that of her father and brothers and there is no indication that she was involved in their actions.”25 The Security Services entry carries the printed name “Marisol X Torres-Soler” against “Signed by:” and the date 10 December 2009; the Approval Information block answers “No” to “Public/High Profile Figure”.3637

2010: a report on a trust, and a search type entered as “None”

The following April the Private Bank completed a due diligence report on a trust, on a variant of the form this page has not shown before. On 22 April 2010 Debra White created and submitted a “USCG Due Diligence Report - Fiduciary” on The Haze Trust, one of the trusts named in the decision-maker record’s own list of reports, with Paul V Morris entered as banker.738 The trust itself, the instrument that created it and its later history at two banks are set out on The Haze Trust and are not repeated here. The report’s summary of findings reads: “This is another part of an existing client relationship with Jeffrey Epstein. The client has requested the opening of a checking account for trust. This trust is for the benefit of Jeffrey Epstein.”, and the anticipated product is “Deposits”.39 The waiver came first and the two approvals nearly three months after it, eight days apart. White requested a temporary waiver on the day she submitted the form, the reason given being “The Senior Manager is out of the office and the Banker is unable to find another senior manager to approve the DDR.”, and the form’s audit history records Elizabeth X Hogan approving that waiver eight minutes after the request; Paul V Morris gave banker approval on 14 July 2010, and Thomas K. Southmayd gave senior manager approval on 22 July 2010, the audit history recording that he did so “on Behalf of Mary C Casey because designated Senior Manager is Senior manager unavailable.”38

Where the 2005 report on Maxwell recorded six categories as “Not researched.” and the 2009 reports recorded “No additional research necessary”, this report records no search result at all.2412 Against “Security Search Type:” the form reads “None”. The “Note for Security Services” field, which invites the banker to list specific search requests, is empty. The Security Services table beneath it carries the same ten rows the other reports fill in, from Company Information to OFAC/Control List Search, and no cell of its “Is Further Review by Banker Required?”, “Security Service Details:” or “Banker Response:” columns carries an entry; the lines above it headed “List Individuals and Corporate Entities Investigated:” and “Attachment:” are blank, and the “Signed by:” and “Dated:” rules below it are blank. Of the two radio buttons following “Has this been identified as a Red Dot DDR? :”, read at 600 dpi against a filled radio button elsewhere in the same report, both rings are open. One line inside the same block is not blank: “Expense No.:” carries the value 102/29338, which is the value the report’s first sheet prints against “LE/OU:” in its banker information block (one of four coded banker fields listed there beneath the banker’s name, and not a search result), while the “Total Costs:” rule beside it is empty.397

Two other due diligence reports on the same fiduciary form, produced earlier in the same Bates run, were opened at the page image for this page, the sheet carrying each one’s Security Services section among them: JPM-SDNY-00002910 and JPM-SDNY-00002932, whose “Dated:” rules read December 2008, about sixteen months before the report on the trust.4041 On each of the two, “Security Search Type” reads “Full”; the “Note for Security Services” field carries the entry “Trust domicile is U.S. Virgin Islands”; an attachment is named; every one of the ten rows of the Security Services table carries an entry in both the “Is Further Review by Banker Required?” and the “Security Service Details:” columns; the “No” radio button after “Has this been identified as a Red Dot DDR? :” is filled, where on the 2010 report both rings are open; and the “Signed by:” and “Dated:” rules carry a printed name and a date, where on the 2010 report they are blank. The “Banker Response:” column is empty on both of them, as it is on the 2010 report. Two reports are not the form family. This page makes no claim about the fiduciary form as a whole, and none about how many reports on that form the run holds: it opened two, and reports that on those two the fields the 2010 report leaves blank carry entries.

What the report does record is two background checks, both dated 22 April 2010 and both recorded against the Morgan Network. In the Non-JPM Trustee(s)/Executor(s) Checks block the comment reads “Jeffrey Epstein is an existing client. Darren Indyke is the attorney for Jeffrey Epstein and an exisiting client.”; in the Grantor Checks block it reads “Jeffrey Epstein is an existing client.”42 Each block lists the same eight possible checks (Morgan Network, TRW/CIC, Lexis Nexis, Dun _Bradstreet, Bank References, Directories, Bus Social Contacts and Other), and in both blocks only the Morgan Network box carries a mark, every other box being empty with empty date and comment cells beside it.4239 Printed above the Grantor Checks block are the form’s own instructions that “At least one Background Check needs to be performed.” and that “At least one Background Check needs to be performed OUTSIDE THE MORGAN NETWORK (Third Party Validation)”.42 The two comparison reports carry the same pattern beneath the same printed instructions: on each of them, in both blocks, the Morgan Network box alone is marked, and every other row of both blocks is empty in its box, its date cell and its comment cell.43

Two dates on the produced copy do not sit together. Its decision-maker table gives twenty-two entries in the “Security Services Search Date” column, the earliest 11 August 1999 and the latest 7 March 2011, while the form’s own document history gives 22 July 2010 as the date it was last modified. Both are on the paper and this page does not reconcile them.738

2011 and 2012: what “derogatory” meant, and what the group said it had not searched

On 24 August 2011 the group “was requested by Paul Morris to conduct a background investigation” for an account titled Pot and Kettle, and five days later, on 29 August 2011, for one titled Ellmax.110 Both reports state that full research was conducted “in FL only”.110 The Pot and Kettle executive summary then records a limit on its own scope and puts a price on removing it:

Investigation indicates Ghislaine Maxwell to have affiliation(s) in CA and the Virgin Islands. Records were not searched in CA and the Virgin Islands, and research may reveal corporate or court records. Research can be completed upon request of the banker and these searches require additional time (two business weeks) and cost.1

Under Maxwell both 2011 reports record that the “Internal database search revealed prior GSI research and the following derogatory information was reported”, and then reproduce the same press items the 2005 form had listed, with one addition, an article of 23 June 2005 about Robert Maxwell’s use of pledged assets.4445 Every item in the list concerns Robert Maxwell, Kevin and Ian Maxwell, the 1996 driving arrest, or the “source of wealth” line of 2000. Still under Maxwell, the same report records that its “Other databases” search now included a sex offender database, that “State court searches revealed no records found,” and that “Federal court searches revealed records found.”44 The Pot and Kettle entity’s own searches, recorded separately later on the same report, found no state or federal court records.46

The same construction appears again on 30 April 2012, when the group was requested by Paul Morris to investigate Terra Mar Project Inc, and again reported the same list of press items under the heading of prior research and derogatory information.1147

2013: an internal database that reported nothing derogatory, and a ticket that called the owner a convicted felon

On 12 February 2013 the group “was requested by Kirsten Sichler to conduct a background investigation.”2 This report is media research only: it records that it searched the internal fraud prevention list, Worldcheck, publications, regulatory sanctions, FINRA/NFA and OFAC, and no company records, no corporate records, no court searches and no personal particulars.2 Under Ghislaine Maxwell it records: “Internal database search revealed prior GS&I research for Ghislaine Maxwell and nothing derogatory was reported.” Under Robert Maxwell it records the same.2

Two reports of the same unit, on the same subject and out of the same internal database, therefore disagree on the paper. In August 2011 and again in April 2012 the internal database search “revealed prior GSI research and the following derogatory information was reported”, followed by five items. In February 2013 it “revealed prior GS&I research for Ghislaine Maxwell and nothing derogatory was reported.”44472 The 2013 report gives no reason for the difference and does not refer to the earlier reports by number.

Five months later the bank was moving the other way on the Epstein side of the file. On 13 July 2013 Justin D Nelson of the Private Bank front office opened know-your-customer tickets on the Epstein-linked accounts.348 The ticket on 116 East 65th St., LLC records an initial and final risk rating of High, gives as its summary of risk attributes “Owner, Jeffrey Epstein, is a convicted felon”, and records the banker’s rationale for conducting business with the client as: “We are in the process of exiting the relationship.”349 Its investigations grid records that the internal database search had returned “prior GS&I research for Jeffrey Edward Epstein and the following derogatory information was reported”, followed by a summary of press coverage of the Florida charges, the sentence served, investigations by law enforcement agencies, sex offender registration, and civil settlements.3 The ticket on the MAX Foundation, opened the same day, records under cash and wire activity “Client is exiting the firm” and, in its additional comments, “At the request of sr management client is exiting the firm.”50 A third ticket of that date, number 105258611, was opened on The Haze Trust, the trust whose fiduciary report is described above; it too records an initial and a final risk rating of High, a GCS report requested of “Full”, and a summary of risk attributes opening “Convicted Felon”.51

On one sheet of that ticket one sentence is entered against seven consecutive questions. Those seven narrative fields ask who the client is known to at JPMorgan and for how long, the overall relationship size and type of accounts, whether this is a shared client, when the banker last met the client, any significant changes in the client’s information over the year, and the cash and wire activity summaries, and each carries the sentence “Client has been asked to exit the firm - in progress.”, one of the seven reading this firm where the others read the firm.52 The additional comments field on the same sheet records client activity “related to exiting assets and accounts” from the Private Bank at the request of senior management, and a Comment History row on that sheet, headed “CEO Approval” and dated 27 November 2013, is entered by John R Duffy with a comment preview recording approval “to facilitate client exit”.52

December 2013 to September 2014: the committee decision and the exit

The last instrument in the sequence is a know-your-customer summary on Ghislaine Maxwell, ticket 1414786507980, headed “KYC One Year Periodic Review”, with an initiated date of 15 February 2014 and James N Buckley recorded as banker.6 Its business case records the decision and the reason for it:

Reputational - 2011 media alleging Maxwell solicited young girls for then boyfriend Jeffrey Epstein. Epstein was convicted for solicitation of a prostitute and procurring a person under age 18 for prostitution. He was the subject of a previous Management Review and has been exited from the Bank. In a 12/6/13 RRC mtg, the decision was made to exit Maxwell. Even though all of Maxwell’s banking accounts have been closed (only credit cards remain), the ticket needs to be completed to close the loop on the exit.13

The form’s spellings are as printed. Against the question asking the banker to state why he is comfortable with the client given the identified risk, the answer reads: “We are no longer comfortable with this client. CLIENT EXITED THE BANK ON REQUEST OF RISK COMMITTEE AND THE LAST ACCOUNTS CLOSED JUNE 8, 2014.”13 The same sentence, in capitals, is entered in a run of other fields on the ticket: in place of an answer for the overall relationship size, the question about other lines of business, and the question about significant changes over the year; and prefixed to substantive text, rather than replacing it, in the fields on the original wealth’s creation and its value when received (see below).1353 The risk assessment field records: “THIS CLIENT EXITED THE BANK AND ASSETS CLOSED JUNE 8, 2014 AS RISK COMMITTEE REQUESTED. KYC completed as a result on a best efforts basis, given client could not be contacted to gather additional informaton.”13 The banker’s attestation records: “Ghislaine Maxwell was asked to leave the bank by our Risk Committee. Her assets have all left the bank and her accounts have all since closed. She is no longer a client of the Private Bank.”13 The ticket names the deciding body twice as the “Risk Committee” and once by the initials “RRC”; it does not expand them.13

The ticket’s risk block records an initial rating of Standard and a final rating of High, with the reason for the adjustment given as “Negative media - human rights issue”; the summary tab of the same ticket records “Risk Factors: No Risk Factors Present”.413 The investigations grid on that page recites the derogatory items in an abbreviated form, keeping the 2000 “source of wealth” line and the 1996 arrest and dropping the rest, and points back to the accounts titled “116 East 65th St LLC” and “Pot and Kettle” “for previous research”.4

The ticket’s own audit trail dates the work. It was composed on 24 June 2014, sixteen days after the closing date it reports; the banker attestation was approved on 12 August 2014, the market manager approval by Mary Casey on 19 August, the regional director approval by William Sheridan on 20 August, and the line-of-business chief executive approval by John Duffy on 24 September 2014.54 The header date of 15 February 2014 and the audit trail’s composition date of 24 June 2014 are both on the paper and this page does not reconcile them.654

What the reports were made of

The bodies of the investigations group’s reports are printouts from commercial databases and press retrieval systems: Dun & Bradstreet company records, an Experian business report, LexisNexis-sourced corporate records, a CourtLink federal court docket, secretary of state filings, and press items retrieved with their retrieval-system fields still attached, so that a report records an article’s section, word count and byline.555657585960 What a commercial database returned is a record of a search, not a finding about a person. The same reports also carry a checklist of possible source types (Lexis Nexis, Dun & Bradstreet, bank references, directories, business/social contacts), with none of the boxes ticked; an unticked checklist is not evidence that a source was used, and this page cites only pages that show the search results themselves.12

One field in the 2014 ticket is not a search result at all. Asked to describe how and when the original wealth was created, the banker entered a narrative of Robert Maxwell’s business career running to several hundred words, carrying the footnote markers “[11]”, “[12]”, “[13]” and “[14]” mid-sentence and a parenthetical cross-reference reading “(see Controversy below)” to a section that does not exist in the ticket.53 It is text pasted into the field from an outside reference work, and it should be read as what the bank put in the field rather than as anything the bank established.

What the file does not settle

The file records what the bank asked for and what it decided, and it is silent or unreadable on several points a reader will want.

The form provides a “Note for Security Services” field for the banker to list specific search requests; on that report the field is empty, and the file does not name who decided which of the six categories to leave unrun.24

It does not record any request to complete the California and Virgin Islands searches the 2011 report offered to run for a fee, and the next report on Maxwell in the file, in February 2013, is media research only.12

It does not reconcile the 2011 and 2012 reports, which say the internal database held derogatory information on Maxwell, with the 2013 report, which says it held nothing derogatory.44472

It does not explain why the 2009 report on a company answers “Yes” to “Public/High Profile Figure” and adds “Prominent person who is perceived to be controversial”, where the 2005 report on Maxwell herself answers “No” to the same question, a “No” that, as noted above, was itself a later edit rather than part of the original 2005 approval.30 The 2010 report on the trust answers “No” to the same question in its own approval block; The Haze Trust carries more of that block.61

And the decision-maker table, which is the only index the file contains of its own contents, cannot be enumerated: two of its name rows are covered and its two columns do not align.5

The documents described here were located by searching the released files for the phrases “GS&I was requested by”, “Not researched”, “Red Dot”, “decision was made to exit Maxwell”, “Confidential Due Diligence Report” and “Security Search Type”, and by reading the Bates run on either side of each result.

The bank’s position

JPMorgan denied all claims, allegations and contentions of fault, liability and wrongdoing in the class action brought on behalf of Epstein’s victims, which the court recorded as settled for $290 million, and the settlement notice records that the court made no ruling on liability.16 In its third-party complaint against Staley the bank stated that it did not admit the allegations of either trafficking complaint and denied all liability.62 After the class settlement it said publicly: “Any association with him was a mistake and we regret it. We would never have continued to do business with him if we believed he was using our bank in any way to help commit heinous crimes.”1716 No statement by the bank addressing these particular due diligence reports appears in the documents cited here.

JPMorgan Chase; Ghislaine Maxwell; Jes Staley; The TerraMar Project; C.O.U.Q. Foundation; Financial Trust Company; The Haze Trust; Darren Indyke; Les Wexner; Southern District of New York; Epstein financial crimes.

Footnotes

  1. JPMorgan Chase, “Confidential Due Diligence Report”, Pot and Kettle, executive summary; report reference 511696411A; JPM-SDNY-00062400. Read from the page image. https://epstein-data.com/EFTA01582825 p.1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  2. JPMorgan Chase, “Confidential Due Diligence Report”, Ghislaine Maxwell, executive summary and findings; report reference 565419813B; JPM-SDNY-00062394. Read from the page image. https://epstein-data.com/EFTA01582820 p.1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  3. JPMorgan know-your-customer ticket 105258583, initiated 13 July 2013, risk ratings and investigations grid; JPM-SDNY-00062533. Read from the page image. https://epstein-data.com/EFTA01582948 p.1. ↩ ↩2 ↩3 ↩4

  4. Same ticket, risk rating, summary of risk attributes and the investigations grid; JPM-SDNY-00062391. https://epstein-data.com/EFTA01582817 p.1. ↩ ↩2 ↩3

  5. JPMorgan Private Bank, “USCG Due Diligence Report - Corporation”, MAX Foundation, banker and decision-maker record; JPM-SDNY-00062352. Read from the page image. https://epstein-data.com/EFTA01582785 p.1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  6. JPMorgan “KYC Summary”, ticket 1414786507980, Ghislaine Maxwell, header and primary information; JPM-SDNY-00062386. Read from the page image. https://epstein-data.com/EFTA01582812 p.1. ↩ ↩2 ↩3

  7. JPMorgan Private Bank, “USCG Due Diligence Report - Fiduciary”, DDR Name “The Haze Trust ~”, DDR Status “Process Completed”, banker Paul V Morris, banker LE/OU 102/29338 (the sheet prints that label unexpanded), the decision-maker record in Jeffrey E Epstein’s name and the table of other reports filed under it; JPM-SDNY-00002994. Read from the page image at 400 dpi and the date column re-read at 600 dpi: the table has twenty-two entries in its “Security Services Search Date” column, every one of which was read, the earliest 08/11/1999 and the latest 03/07/2011; two of its name rows are covered by black bars, and in the lower part of the table the name column runs on past the banker and date columns, so the two cannot be paired by eye there. https://epstein-data.com/EFTA01480772 p.1. Every reading on this page is taken from this, the laid-out copy of the report, whose seven sheets are the single-page run EFTA01480772 to EFTA01480778. A second copy exists as a thirteen-page run in which the tables are flattened into single columns of text so that labels and values fall into separate stacks: https://epstein-data.com/EFTA01481894 pp.1–13. ↩ ↩2 ↩3 ↩4

  8. JPMorgan Chase, “Confidential Due Diligence Report”, 116 East 65th Street., LLC, executive summary; JPM-SDNY-00062431. https://epstein-data.com/EFTA01582853 p.1. ↩ ↩2 ↩3 ↩4

  9. JPMorgan Chase, “Confidential Due Diligence Report”, Max Foundation, executive summary; JPM-SDNY-00062360. Read from the page image. https://epstein-data.com/EFTA01582791 p.1. ↩ ↩2 ↩3 ↩4

  10. JPMorgan Chase, “Confidential Due Diligence Report”, Ellmax, executive summary; report reference 511938611A; JPM-SDNY-00062344. https://epstein-data.com/EFTA01582777 p.1. ↩ ↩2 ↩3 ↩4

  11. JPMorgan Chase, “Confidential Due Diligence Report”, Terra Mar Project Inc, executive summary; report reference 541823112A. https://epstein-data.com/EFTA01594211 p.1. ↩ ↩2 ↩3

  12. JPMorgan Private Bank, “USCG Due Diligence Report - Corporation”, 116 East 65th St., LLC, Security Services table, sign-off, background checks and summary of findings; JPM-SDNY-00062427. Read from the page image. https://epstein-data.com/EFTA01582849 p.1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  13. Same ticket, additional comments, business case, risk assessment and banker attestation; JPM-SDNY-00062390. Read from the page image. https://epstein-data.com/EFTA01582816 p.1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  14. WilmerHale to the U.S. Attorney’s Office for the Southern District of New York, Sept 2, 2020, and Appendix A. https://epstein-data.com/EFTA00096342 pp.1-2, 4-5. ↩ ↩2

  15. Same report, continuation of the Security Services table, the Publications row, the Security Services sign-off and the Individual Checks block; JPM-SDNY-00062439. Read from the page image. https://epstein-data.com/EFTA01582860 p.1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  16. Notice of Proposed Settlement of Class Action, Jane Doe 1 v. JPMorgan Chase Bank, N.A., 1:22-CV-10019 (JSR). https://epstein-data.com/EFTA00146745 pp.1, 4-5, 11. ↩ ↩2 ↩3

  17. Statement of Material Facts as to Which the Government of the United States Virgin Islands Contends There Is No Genuine Dispute, 22-cv-10904 (JSR), Doc. 221, Jul 24, 2023. https://epstein-data.com/EFTA02809437 pp.1-2. ↩ ↩2

  18. House Committee on Oversight and Government Reform, transcribed interview of James Edward “Jes” Staley, July 24, 2026, printed pp.22-24 (the 2005 banker response and the account), 88-89 (the general counsel in 2009), 111-112 (what a due diligence report is), 116-117 (the 2004 report and the answer to it). https://oversight.house.gov/wp-content/uploads/2026/08/Jes-Staley-Final-Transcript_Redacted-8.26.26.pdf ↩ ↩2 ↩3 ↩4 ↩5

  19. JPMorgan Chase, Security Services check begun 11 March 2003, Ghislaine Maxwell; JPM-SDNY-00062484. Read from the page image. https://epstein-data.com/EFTA01582902 p.1. ↩ ↩2 ↩3

  20. Same 2003 form, summary of findings, number assignments and approval blocks; JPM-SDNY-00062487. Read from the page image. https://epstein-data.com/EFTA01582905 p.1. ↩

  21. Same report, Approval Information, Temporary Waiver Information and the banker and senior manager approval blocks; JPM-SDNY-00062441. Read from the page image. https://epstein-data.com/EFTA01582862 p.1. ↩ ↩2 ↩3 ↩4

  22. JPMorgan Private Bank, “USCG Due Diligence Report - Individual”, Ghislaine Maxwell, introduction and financial information; JPM-SDNY-00062437. https://epstein-data.com/EFTA01582858 p.1. ↩

  23. JPMorgan Private Bank, “USCG Due Diligence Report - Individual”, Ghislaine Maxwell, 2005, produced whole as a second, twelve-page copy of the same report cited above at 22, 24, 15 and 21; Individual Checks comment and summary of findings. The date-of-birth field is redacted on this copy. https://epstein-data.com/EFTA01594255 p.9. ↩

  24. Same report, Required Security Services Checks and the first rows of the Security Services table; JPM-SDNY-00062438. Read from the page image. https://epstein-data.com/EFTA01582859 p.1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  25. JPMorgan Private Bank, “USCG Due Diligence Report - Corporation”, MAX Foundation, Security Services Information and the Red Dot section; JPM-SDNY-00062355. Read from the page image. https://epstein-data.com/EFTA01582787 p.1. ↩ ↩2 ↩3

  26. Same second, whole-document copy; document history and audit history. https://epstein-data.com/EFTA01594255 p.12. ↩

  27. JPMorgan Private Bank, “USCG Due Diligence Report - Individual”, 2004, financial information and required security services checks; the subject’s name is withheld. https://epstein-data.com/EFTA01582809 p.1. ↩ ↩2

  28. Same report, Security Services table, sign-off, Individual Checks and summary of findings; JPM-SDNY-00062383. https://epstein-data.com/EFTA01582810 p.1. ↩ ↩2 ↩3 ↩4

  29. Same report, number assignments and the banker and senior manager approval blocks; JPM-SDNY-00062384. https://epstein-data.com/EFTA01582811 p.1. ↩

  30. Same report, the final clause of the summary of findings quoted above, client hierarchy assignments and Approval Information; JPM-SDNY-00062428. Read from the page image. https://epstein-data.com/EFTA01582850 p.1. ↩ ↩2 ↩3 ↩4

  31. Same report, findings on Robert Maxwell, 116 East 65th St., LLC and Ghislaine Maxwell; JPM-SDNY-00062432. https://epstein-data.com/EFTA01582854 p.1. ↩ ↩2 ↩3

  32. JPMorgan Private Bank, due diligence report on a life insurance trust; its summary of findings begins on JPM-SDNY-00002910 and the cell continues at the head of the next produced sheet of the same report, JPM-SDNY-00002911. Read from the page image at 400 dpi: the remainder of the cell is the two sentences quoted above, and the “Anticipated Product(s)” row printed immediately beneath the cell reads “Deposits”. https://epstein-data.com/EFTA01480696 p.1. ↩

  33. JPMorgan Private Bank, due diligence report on a second life insurance trust, the sheet carrying the Summary block; JPM-SDNY-00002932. Read from the page image at 400 dpi: the “Summary Of Findings” cell runs to two paragraphs, the first reading “Jeffrey Epstein is a PB client of over 10 years. This account is for a life insurance trust.” and the second being the sentences quoted above, and the “Anticipated Product(s)” row beneath the cell reads “Deposits”. The extraction of this sheet damages one name in the second paragraph, which is why the cell is read at the image. https://epstein-data.com/EFTA01480716 p.1. ↩

  34. Same report, banker, senior manager and area head approvals, quality review, document history and audit history; JPM-SDNY-00062429. Read from the page image. https://epstein-data.com/EFTA01582851 p.1. ↩

  35. Same report, findings on Ghislaine Noelle Maxwell; JPM-SDNY-00062362. https://epstein-data.com/EFTA01582793 p.1. ↩

  36. Same report, continuation of the Red Dot section, Security Services sign-off, background checks and summary of findings; JPM-SDNY-00062356. https://epstein-data.com/EFTA01582788 p.1. ↩

  37. Same report, client hierarchy assignments, Approval Information and waiver status; JPM-SDNY-00062357. https://epstein-data.com/EFTA01582789 p.1. ↩

  38. Same report, laid-out copy, the sheet carrying Annual/Periodic Review, Temporary Waiver Information, the banker and senior manager approval blocks, document history and audit history; JPM-SDNY-00003000. Read from the page image at 400 dpi: the document history records the report created and submitted on 04/22/2010 by Debra White, and the “Reason for Waiver” field is quoted above in full. The clock times on the audit history carry no time zone and none is printed here; the eight-minute interval between the waiver request and its approval is the difference between two entries on that one audit history. https://epstein-data.com/EFTA01480778 p.1. ↩ ↩2 ↩3

  39. Same report, laid-out copy, the sheet carrying the last rows of the Grantor Checks list, Required Security Services Checks, the Security Services table, the Red Dot question and the Summary; JPM-SDNY-00002998. Read from the page image at 400 dpi, all ten rows of the table read; the two radio buttons after “Has this been identified as a Red Dot DDR? :” were re-examined at 600 dpi on the native raster, where both rings are open, and compared with the filled radio button in the “Existing Client” group on the report’s first sheet. https://epstein-data.com/EFTA01480776 p.1. ↩ ↩2 ↩3

  40. The two comparison reports, opened at the page image for this page. JPMorgan Private Bank, due diligence report, the sheet carrying Required Security Services Checks and the Security Services table; JPM-SDNY-00002910; read from the page image at 400 dpi; its summary of findings begins “Jeffrey Epstein is a PB client of over 10 years. This account will fund insurance premiums for a life insurance trust.” and continues at the head of the next produced sheet, JPM-SDNY-00002911, where it records the decision on Epstein quoted in the 2009 section above; https://epstein-data.com/EFTA01480695 p.1. And the same sheet of a second report; JPM-SDNY-00002932; read from the page image at 400 dpi; https://epstein-data.com/EFTA01480716 p.1. Ten rows of each table were read, and the radio buttons and the “Signed by:” and “Dated:” rules with them. The names printed against “Signed by:” on the two sheets are described here and not quoted. ↩

  41. How the form variant of each comparison report was established. For JPM-SDNY-00002910, the preceding sheet of the same produced run, JPM-SDNY-00002909, read from the page image at 300 dpi, carries the “Non-JPM Trustee(s)/Executor(s) Checks” and “Grantor Checks” blocks that mark the fiduciary variant; https://epstein-data.com/EFTA01480694 p.1. For JPM-SDNY-00002932, the first sheet of the same produced run, JPM-SDNY-00002928, read from the page image at 300 dpi, carries the form title “USCG Due Diligence Report - Fiduciary” and the DDR name “The 2007 Jeffrey E Epstein Insurance Trust #2 - November 1, 2007 ~”; https://epstein-data.com/EFTA01480712 p.1. ↩

  42. Same report, laid-out copy, the sheet carrying the Non-JPM Trustee(s)/Executor(s) Checks block, the printed instructions above the Grantor Checks block and the first five rows of that block; JPM-SDNY-00002997. Read from the page image at 400 dpi: in each block the box beside “Morgan Network” carries a mark and that row alone carries a date and a comment. The last three rows of the Grantor Checks list continue onto the following sheet, JPM-SDNY-00002998, cited in the note immediately above. https://epstein-data.com/EFTA01480775 p.1. ↩ ↩2 ↩3

  43. The background-check blocks of the two comparison reports. For JPM-SDNY-00002910, the preceding sheet of the same produced run, JPM-SDNY-00002909, read from the page image at 400 dpi, carries the whole of the Non-JPM Trustee(s)/Executor(s) Checks block and the first four rows of the Grantor Checks block beneath the printed instructions; https://epstein-data.com/EFTA01480694 p.1. The last four rows of that Grantor Checks block stand at the head of the next sheet, JPM-SDNY-00002910, read from the page image at 400 dpi; https://epstein-data.com/EFTA01480695 p.1. For JPM-SDNY-00002932, both blocks stand whole on JPM-SDNY-00002931, read from the page image at 400 dpi; https://epstein-data.com/EFTA01480715 p.1. All eight rows of each of the four blocks were read. ↩

  44. Same report, findings on Ghislaine Maxwell and on Pot and Kettle; JPM-SDNY-00062401. Read from the page image. Other rows of the findings table are not quoted here. https://epstein-data.com/EFTA01582826 p.1. ↩ ↩2 ↩3 ↩4

  45. Same report, findings on Ellmax and on Ghislaine Maxwell; JPM-SDNY-00062345. https://epstein-data.com/EFTA01582778 p.1. ↩

  46. Same report, findings on Pot and Kettle continued: other databases, court searches and publications; JPM-SDNY-00062402. https://epstein-data.com/EFTA01582827 p.1. ↩

  47. Same report, findings on Ghislaine Maxwell, Robert Maxwell and Terra Mar Project Inc. https://epstein-data.com/EFTA01594211 p.2. ↩ ↩2 ↩3

  48. JPMorgan know-your-customer ticket 105258608, MAX Foundation, initiated 13 July 2013; JPM-SDNY-00062375. https://epstein-data.com/EFTA01582802 p.1. ↩

  49. Same ticket, banker rationale and primary information for 116 East 65th St., LLC; JPM-SDNY-00062534. https://epstein-data.com/EFTA01582949 p.1. ↩

  50. Same ticket, cash and wire activity and additional comments. https://epstein-data.com/EFTA01582805 p.1. ↩

  51. JPMorgan know-your-customer ticket 105258611, THE HAZE TRUST, initiated 07/13/2013 with a clock time that carries no time zone, so no clock time is printed here; initiator Justin D Nelson of the PB Front Office; risk ratings, GCS report requested, Summary of Risk Attributes, GCS Grid and Banker Attestation Details; JPM-SDNY-00002987. Read from the page image at 400 dpi. https://epstein-data.com/EFTA01480766 p.1. The pins here read the laid-out copy of this ticket, whose sheets are the single-page run EFTA01480766 to EFTA01480771; a second, nineteen-page copy in which the tables are flattened is at https://epstein-data.com/EFTA01481875 pp.1–19. ↩

  52. Same ticket, laid-out copy, the sheet carrying the banker’s narrative fields, the Expected Activity block, Additional Client Information, Comment History and the head of the Approval History; JPM-SDNY-00002992. Read from the page image at 400 dpi and the seven narrative answers re-read at 600 dpi: six read “Client has been asked to exit the firm - in progress.” and on the third the word reads this firm rather than the firm. The extraction of this sheet damages that sentence in six of the seven cells and damages the additional-comments text, which is why both are read at the image; the Comment History row’s date carries a clock time with no time zone and none is printed here. https://epstein-data.com/EFTA01480771 p.1. ↩ ↩2

  53. Same ticket, source of wealth and inheritance narrative; JPM-SDNY-00062388. https://epstein-data.com/EFTA01582814 p.1. ↩ ↩2

  54. Same ticket, audit trail; JPM-SDNY-00062392. Read from the page image. https://epstein-data.com/EFTA01582818 p.1. ↩ ↩2

  55. JPMorgan Chase, Dun & Bradstreet company report attached to the 2005 individual due diligence report on Ghislaine Maxwell; JPM-SDNY-00062444. https://epstein-data.com/EFTA01582864 p.1. ↩

  56. Same attachment bundle, Experian Business Reports printout; JPM-SDNY-00062451. https://epstein-data.com/EFTA01582871 p.1. ↩

  57. Same attachment bundle, corporate records search sourced to LexisNexis; JPM-SDNY-00062454. https://epstein-data.com/EFTA01582873 p.1. ↩

  58. Same attachment bundle, federal court docket sourced to CourtLink; JPM-SDNY-00062468. https://epstein-data.com/EFTA01582887 p.1. ↩

  59. JPMorgan Chase, “Confidential Due Diligence Report”, Max Foundation, New York Secretary of State corporate filing; JPM-SDNY-00062367. https://epstein-data.com/EFTA01582797 p.1. ↩

  60. JPMorgan Chase, 2005 individual due diligence report attachment, press item with section, length and byline fields; JPM-SDNY-00062481. https://epstein-data.com/EFTA01582899 p.1. ↩

  61. Same report, laid-out copy, the sheet carrying Client Hierarchy Assignments and Approval Information; JPM-SDNY-00002999. Read from the page image at 400 dpi: the Approval Information block answers “No” to “Public/High Profile Figure”. Tax identification numbers on this page are not reproduced here. https://epstein-data.com/EFTA01480777 p.1. ↩

  62. JPMorgan Chase Bank, N.A.’s Third-Party Complaint against James Edward Staley, USVI v. JPMorgan, 22-cv-10904 (JSR), Doc. 70, Mar 8, 2023. https://epstein-data.com/EFTA02806526 pp.1-4. ↩

Backlinks