USVI Attorney General Complaint Against Epstein Estate

Overview of the USVI Complaint

On January 15, 2020, the U.S. Virgin Islands Department of Justice, acting through then-Attorney General Denise George, filed a civil enforcement action against the estate of Jeffrey Epstein. The complaint alleged that Epstein used the U.S. Virgin Islands and USVI-based corporate entities as an integral part of a criminal enterprise involving the trafficking and sexual abuse of young women and girls over a period spanning more than two decades.

The USVI AG complaint was significant not only for its substantive allegations — which provided the most detailed government account of Epstein's operations on his private islands — but also because it ultimately led to $150 million in settlements from two of the world's largest financial institutions, JPMorgan Chase and Deutsche Bank, for their roles in facilitating Epstein's activities.

The Legal Basis

The complaint was filed under USVI consumer protection and anti-racketeering statutes, alleging that Epstein's corporate entities violated territorial laws by engaging in a pattern of criminal activity. The key legal theories included:

Consumer protection violations. The complaint alleged that Epstein's businesses engaged in deceptive practices by using legitimate-appearing corporate structures to facilitate criminal activity, harming the people and reputation of the U.S. Virgin Islands.

Racketeering. Drawing on USVI anti-racketeering law, the complaint alleged that Epstein and his associates operated an enterprise that engaged in a pattern of criminal conduct, including sex trafficking, sexual abuse of minors, and forced labor.

Unlawful business practices. The complaint alleged that Epstein's USVI-based entities operated in violation of territorial law by facilitating and concealing criminal activity.

Epstein's USVI Corporate Structure

One of the most significant aspects of the USVI complaint was its detailed description of the corporate structure Epstein established in the territory. The complaint identified several entities:

Southern Trust Company, Inc. A USVI-based company that served as Epstein's primary business entity in the territory. The complaint alleged that this entity was used to manage Epstein's island properties, employ staff, and conduct financial transactions related to his operations.

Other corporate entities. The complaint identified additional companies and trusts registered in the USVI that were allegedly used to hold assets, manage properties, and provide a veneer of legitimate business activity to what prosecutors characterized as a criminal enterprise.

Tax benefits exploitation. The complaint alleged that Epstein exploited USVI economic development programs — designed to attract legitimate business investment to the territory — to obtain substantial tax benefits while actually using the territory as a base for criminal operations. Epstein received significant tax incentives through the USVI's Economic Development Commission program.

The Island Operations

The complaint provided the most detailed government account to date of Epstein's operations on his private islands in the USVI:

Little St. James

Epstein purchased Little St. James, a 70-acre island in the U.S. Virgin Islands, in 1998. Over the following years, he developed the island extensively, constructing:

• A main residential compound
• Guest houses and staff quarters
• A library and office building
• Recreational facilities
• Helicopter landing pads
• Dock facilities

The complaint alleged that Little St. James was the primary location where Epstein brought victims for sexual abuse, describing it as the "principal base of operations" for his trafficking enterprise. Victims were allegedly transported to the island via private aircraft (flying into St. Thomas) and then by helicopter or boat to Little St. James.

Great St. James

Epstein purchased the larger neighboring island, Great St. James (approximately 165 acres), in 2016. The complaint alleged that Epstein began developing this island as well, though it was less extensively built out than Little St. James at the time of his death.

Isolation as Control

The complaint emphasized that the islands' geographic isolation was a deliberate element of Epstein's operation. Victims who were brought to Little St. James were effectively stranded — they had no means of leaving the island without Epstein's approval and assistance. This isolation was described as a tool of coercion that gave Epstein and his associates total control over victims during their time on the islands.

Victim Allegations

The complaint described the experiences of victims who were brought to the USVI:

Recruitment and transport. Young women and girls were allegedly recruited in the continental United States and abroad, with promises of modeling work, educational opportunities, or paid employment. They were transported to the USVI on Epstein's private aircraft.

Conditions on the islands. Victims described controlled conditions on the islands, including confiscation of passports and personal identification documents, restrictions on communication with the outside world, and an environment of intimidation and coercion.

Age of victims. The complaint alleged that victims brought to the islands included girls as young as 12 years old. It described a pattern in which Epstein sought increasingly younger victims over time.

Scope and duration. The complaint alleged that the trafficking and abuse continued from at least the late 1990s through 2019 — up to the time of Epstein's arrest — contradicting earlier assumptions that Epstein had ceased his criminal activity after the 2008 plea deal.

The USVI Government's Knowledge

The complaint raised uncomfortable questions about the USVI government's own relationship with Epstein. Epstein had been a significant presence in the territory for over two decades, employing local staff, purchasing property, and engaging with territorial government officials. The complaint notably came after Epstein's death, raising questions about why the territorial government had not acted sooner.

Following the filing, Attorney General Denise George was fired by then-USVI Governor Albert Bryan Jr. in January 2023, reportedly in connection with her decision to file the complaint and related litigation against JPMorgan Chase. The circumstances of her removal were controversial and raised questions about potential conflicts of interest within the USVI government.

The JPMorgan Chase and Deutsche Bank Settlements

The USVI complaint laid the groundwork for separate but related litigation against two major financial institutions:

JPMorgan Chase Settlement ($75 Million)

The USVI filed a separate action against JPMorgan Chase, alleging that the bank had maintained banking relationships with Epstein for years despite knowledge of his criminal conduct. The complaint alleged that JPMorgan facilitated Epstein's operations by processing financial transactions, maintaining accounts, and failing to file Suspicious Activity Reports (SARs) as required by the Bank Secrecy Act.

In September 2023, JPMorgan agreed to pay $75 million to settle the USVI's claims. The settlement included no admission of wrongdoing by the bank.

Deutsche Bank Settlement ($75 Million)

A parallel action against Deutsche Bank alleged similar failures. Deutsche Bank had taken over as Epstein's primary bank after JPMorgan closed his accounts. The complaint alleged that Deutsche Bank processed hundreds of transactions that should have triggered compliance alerts and ignored red flags about Epstein's activities.

Deutsche Bank settled with the USVI for $75 million in November 2023. The bank had previously paid a $150 million penalty to the New York State Department of Financial Services in 2020 for compliance failures related to its Epstein relationship.

Total Recovery

Combined, the settlements recovered $150 million for the U.S. Virgin Islands, with funds designated for victim compensation and territorial programs. The settlements represented some of the largest financial recoveries in any Epstein-related litigation.

The Epstein Victims' Compensation Program

Separate from the USVI litigation, the Epstein estate established a Victims' Compensation Program that processed claims from individuals who alleged abuse by Epstein. The program, administered by an independent claims administrator, ultimately paid out approximately $121 million to over 135 claimants. The USVI complaint and related proceedings were instrumental in identifying the scope of victimization and facilitating access to compensation.

Significance of the Complaint

The USVI AG complaint is significant for several reasons:

Most detailed government account of island operations. The complaint provided the most comprehensive official description of how Epstein used his private islands as a base for trafficking and abuse.

Corporate structure exposure. By detailing Epstein's USVI corporate entities and his exploitation of tax benefit programs, the complaint revealed the infrastructure that supported his criminal enterprise.

Financial institution accountability. The complaint established a legal framework that led to substantial settlements from JPMorgan Chase and Deutsche Bank, demonstrating that financial institutions that turn a blind eye to trafficking can face significant consequences.

Ongoing activity allegation. The complaint's assertion that Epstein continued criminal activity through 2019 challenged the narrative that his criminal conduct ended with the 2008 plea deal.

Sources and Further Reading

• U.S. Virgin Islands Department of Justice
• JPMorgan Chase Settlement Agreement (September 2023)
• Deutsche Bank Settlement Agreement (November 2023)
• New York State DFS Consent Order re: Deutsche Bank (July 2020)
• Epstein Victims' Compensation Program Final Report