U.S. Virgin Islands Demands JPMorgan Chase Implement New Policies to Prevent Human Trafficking

(New York, NY) – Today the U.S. Virgin Islands Department of Justice filed a brief in the United States District Court in the Southern District of New York detailing the government’s requested remedies in the case Government of Virgin Islands v. JP Morgan Chase Bank.

The new legal filing explains that the USVI seeks to require JPMorgan Chase to implement new policies, including separating its business and compliance functions and designating an independent compliance consultant, to prevent human trafficking. The USVI also estimates a request for penalties and disgorgement of at least $190 million, in addition to other damages.

“We are pursuing this enforcement action because JPMorgan Chase’s institutional failure enabled Jeffrey Epstein’s sex trafficking, and JPMorgan Chase must make significant changes to detect, report and stop human trafficking,” said U.S. Virgin Islands Attorney General Ariel Smith. “Financial penalties, as well as conduct changes, are important to make sure that JPMorgan Chase knows the cost of putting its own profits ahead of public safety. The Virgin Islands will devote funds from any recovery in the case to support efforts to strengthen, inform, and expand local law enforcement and enhance the Virgin Islands’ services for victims of human trafficking and other victims of crime. I am gratified that the victims have received some measure of compensation from the bank, but more needs to be done to hold JPMorgan Chase accountable and to ensure this does not happen to another generation of women and girls.”

The USVI DOJ’s goal with each and all of these remedies is to deter human trafficking in the future. Guided by testimony from human trafficking experts Robert L. Jackson, Jr., former Commissioner of the U.S. Securities and Exchange Commission; Bridgette Carr, Co-Director of the Human Trafficking Clinic + Lab at the University of Michigan Law School and co-creator of the University of Michigan’s Human Trafficking Collaborative; and Jonathan J. Rusch, Director of the U.S. and International Anti-Corruption Law Program at American University, the brief outlines remedies that address JPMorgan Chase’s failure to comply with federal law and aim to ensure the institution never again prioritizes profit over prevention of human trafficking.

The additional safeguards JPMorgan Chase should implement to protect young women and girls, as outlined in the USVI DOJ’s brief, in consultation with human trafficking experts, include:

  •  Making structural institutional changes that would separate its business and compliance functions;
  • Engaging an independent compliance consultant to provide “independent oversight of reporting-related risk” to ensure JPMorgan Chase does not prioritize profits over its duty to report suspicious activities;
  • Analyzing – in collaboration with victims of trafficking and human trafficking experts – the root causes of the bank’s failures in its banking relationship with Jeffrey Epstein and identifying the missed opportunities to report his criminal activities;
  • Prohibiting the participation of employees with personal relationships to clients in decisions related to retaining those clients;
  • Preventing the opening of new banking accounts without identifying basic details from customers;
  • And ensuring non-abusive financial products and protocols to protect victims of human trafficking.

As the Virgin Islands’ previous legal filings allege, JPMorgan Chase enabled Jeffrey Epstein’s heinous sex trafficking scheme, violating the Trafficking Victims Protection Act when it did business with and for Epstein and did not report financial signs of Epstein’s illegal activities. Under federal law, banks have a legal responsibility to report suspicious activity to law enforcement and ensure they do not participate in human trafficking.

The trial in the case Government of Virgin Islands v. JP Morgan Chase Bank is set to begin on Oct. 23.


July 14, 2023
Sandra Goomansingh
Media Relations Director
(340)774-5666 ext. 10105
Email: Sandra.goomansingh@doj.vi.gov