The Virgin Islands, which sued the bank last month, filed an amended complaint in Manhattan federal court on Tuesday claiming that Staley had a “profound” friendship with Epstein and may have been involved in his sex-trafficking ring. 

A lawyer for Staley, who isn’t named as a defendant in the suit, responded Wednesday to deny the allegations that the banker helped facilitate sex trafficking. 

Staley was forced to step down as chief executive officer of Barclays Plc in 2021 amid a UK regulatory probe into how he characterized his past ties to Epstein, who was found dead in his US jail cell in 2019.

Charitable Fund

Epstein and Staley exchanged about 1,200 emails over the course of 10 years, according to the amended complaint. It offers details about the business relationship between the two, including a plan discussed in 2011 between Staley and Epstein to establish a “very HIGH profile” charitable fund. Epstein, the amended complaint says, pitched the idea as an “exclusive club” with a minimum $100 million donation and that JPMorgan would act as the fiduciary.

JPMorgan “allowed Staley to remain a decision maker on Epstein’s accounts,” according to the amended complaint.

A spokesperson for New York-based JPMorgan declined to comment. 

During his tenure as a JPMorgan customer between 1998 and 2013, the bank serviced about 55 accounts for Epstein containing “hundreds of millions of dollars,” the amended complaint states. The accounts were used to pay Epstein’s victims — in one instance, $600,000 — and the recruiters who helped find them, the USVI alleges.

Red Flags

The transactions, including offshore transfers and foreign currency conversions, should have raised red flags, the USVI claims. The suit is seeking unspecified damages for what it says were violations of sex-trafficking, bank-secrecy and consumer laws.

The USVI suit makes similar claims to those contained in proposed class actions filed in November by Epstein victims against JPMorgan and Deutsche Bank AG.

The office of USVI Attorney General Denise George, who was removed from her post at the end of 2022 just days after the suit was filed, conducted an investigation into Epstein’s activities and presented the findings to JPMorgan in September. According to the complaint, the USVI probe found that the bank “pulled the levers through which recruiters and victims were paid” and was indispensable to the operation of Epstein’s trafficking enterprise. 

Epstein for decades cultivated the ultra-wealthy including lingerie titan Les Wexner and Apollo Global Management Inc. co-founder Leon Black, who paid him in excess of $150 million for providing financial advice. 

Wexner has said he cut ties with Epstein in 2007 and later accused him of deception and misappropriating “vast sums of money from me and my family.” Black made clear he had no knowledge of Epstein’s abuse of underage girls and a report by law firm Dechert commissioned by Apollo’s board, said he wasn’t involved in Epstein’s criminal activities. Black, who’s worth $10.5 billion, according to the Bloomberg Billionaires Index, was forced to step down as chairman of Apollo.

Epstein was arrested and charged with sex-trafficking by Manhattan federal prosecutors in 2019 and his former girlfriend, Ghislaine Maxwell, was convicted of similar charges in December 2021. 

During her trial, a JPMorgan banker testified that Epstein wired her $31 million, money prosecutors characterized as Maxwell’s payment for procuring young girls for the financier.

The case is USVI v. JPMorgan Chase Bank, 22-cv-10904-UA, US District Court, Southern District of New York (Manhattan).