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In April 2002, JPMorgan Chase raised a red flag about Jeffrey Epstein.
The bank had noticed his accounts were cashing an unusual number of checks, many for $9,500 or $9,800—just under the $10,000 limit that draws increased attention.
JPMorgan filed what’s known as a suspicious activity report, or SAR, to federal law enforcement because of a clear pattern of transactions typically meant to evade authorities.
The bank would file another report in December 2002 and another in April 2003. The flags were raised well before any public knowledge of Epstein’s crimes and associations with girls and young women, but had little impact on his activities.
The bank would file another report in December 2002 and another in April 2003. The flags were raised well before any public knowledge of Epstein’s crimes and associations with girls and young women, but had little impact on his activities.
Epstein would be arrested in Florida three years later, plead guilty in 2008, and then continue his extravagant lifestyle until 2019. He would remain a JPMorgan client until 2013, meeting with top executives from the bank and connecting them with his wealthy associates, including Leon Black and Bill Gates.
The documents show the knots JPMorgan and all banks can tie themselves in, especially with lucrative clients. On the one hand, they are filing reports warning law enforcement that their client looks suspiciously criminal. But unless their regulators or law enforcement reply otherwise, the banks can continue to serve the client, having fulfilled their obligation with the SAR.
A JPMorgan spokeswoman said the SARs show the bank filed concerns early on and repeatedly about Epstein. “It does not appear that anyone in the government or law enforcement acted on those SARs for years,” the spokeswoman said.
The reports are sent to the Financial Crimes Enforcement Network, part of the Treasury Department, which monitors the financial system for crimes such as money laundering and makes the reports available to law enforcement. Treasury representatives declined to comment Friday.
The red flags were raised internally at the bank throughout its relationship with Epstein, who had dozens of accounts and moved millions of dollars. At one point, Epstein and his associates told JPMorgan staff the cash was needed to pay for fuel for his private jet, but some JPMorgan staffers were skeptical especially after media coverage of Epstein’s 2006 arrest in Florida showed he was paying for sex with minors.
In 2008, the bank filed another SAR on Epstein, citing the prosecution and flagging $800,000 in withdrawals in 2007 and 2008.
In an email exchange in 2013, JPMorgan staffers discussed whether they should include concerns in a SAR about Epstein potentially using the cash to pay for sex, not just for jet fuel. The bank did file a SAR raising concerns about the fuel story, showing one Epstein account took out more than $200,000 in cash in 2011 and $290,000 in 2012.
“I think we should stick to taking out cash and traveling abroad to pay for fuel is not normal business practice. True, he has been known to pay cash for his massages but only minors are the issue and we have no proof,” one JPMorgan staffer wrote.
Once the bank decided to close Epstein’s accounts in 2013, another JPMorgan staffer wrote to Mary Erdoes, who oversaw the private bank, saying Epstein had called him. “Still looking for closure. Understands better now the impact of his cash activities—sticking to aviation needs,” he wrote.
In the same message, the banker asked his boss whether JPMorgan could continue to work with Epstein through his clients’ accounts.
Erdoes replied with a single letter: “Y.”
Erdoes has said she didn’t know about his crimes and the bank has said it regrets its relationship with Epstein.
In 2016, JPMorgan filed additional SARs that found that Epstein had sent more than $310,000 to a former model. The bank flagged the transfers for “possible procurement of sexual” services.
The documents originate from a 2023 case that the U.S. Virgin Islands attorney general filed against JPMorgan, alleging that the bank facilitated Epstein’s sex trafficking operation. JPMorgan agreed to pay $75 million that year to settle the suit before it went to trial, without admitting wrongdoing.
The case exposed how deep Epstein’s ties were with the bank. He introduced prominent clients and pitched executives on big deals. Bankers also continued meeting with him after firing him as a client in 2013.
Officials at the Gates Foundation also were also well aware of Epstein’s checkered past in 2011 when the organization was in discussions with Epstein and JPMorgan executive Jes Staley on creating a potential charitable fund for super wealthy individuals.
“Bill and Jes share a mutual ‘friend’ in Jeff Epstein (an important behind the scenes ‘broker’ in the finance world with an unseemly reputation due to a criminal conviction: From JPM, we know that Jeff has the ear of Jes and has helped recruit (behind the scenes) some of JPM’s biggest clients,” according to a Gates Foundation memo.
Gates has said it was a mistake to meet with Epstein. Staley, who left JPMorgan and went on to run Barclays, has maintained he never knew about Epstein’s alleged crimes.
Epstein was arrested again in 2019 and died in prison that August. Three days after his death, JPMorgan began filing SARs detailing even more of his history. The bank eventually reported more than $1 billion in transactions connected to Epstein associates, including Victoria’s Secret billionaire Les Wexner and hedge-fund manager Glenn Dubin.
Black has said he paid Epstein for estate-planning and tax advice. Wexner has said he was defrauded by Epstein, his money manager, and cut him off in 2007. Dubin has said he was unaware of Epstein’s alleged crimes.
The filing said the wires were “consistent with negative media involving sex trafficking of minors” and alerted the regulator to Epstein’s activity in Russia.
Write to David Benoit at David.Benoit@wsj.com, Joe Palazzolo at Joe.Palazzolo@wsj.com and Khadeeja Safdar at khadeeja.safdar@wsj.com