An Open Letter to Congressman James Comer, Chair of the House Oversight and Government Reform Committee ~
September 2, 2025 ~
Dear Chairman Comer:
On August 31 you sent a letter to U.S. Treasury Secretary Scott Bessent seeking, no later than September 15, all Suspicious Activity Reports (SARs) filed by banks “in reference to or relating to Mr. Jeffrey Epstein and/or Ghislaine Maxwell.”
Your letter of August 31 follows a letter dated July 21 that Senator Ron Wyden, the Ranking Member of the U.S. Senate Finance Committee, sent to U.S. Attorney General Pam Bondi. In that letter, Senator Wyden reveals that bipartisan staff of the Senate Finance Committee were allowed earlier this year to look at the SARs material you are seeking from the U.S. Treasury, but not make copies. Senator Wyden writes:
“On February 14, 2024, bipartisan staff of the Senate Finance Committee conducted in camera review of thousands of pages of Treasury Department files documenting the flow of money in and out of Jeffrey Epstein’s accounts. The Treasury Department’s Epstein file contains significant information on the sources of funding behind Epstein’s sex trafficking activities. For example, one of the documents in the Treasury Department’s Epstein file indicates that between 2003 – 2019, there were more than 4,725 wire transfers totaling $1.08 billion involving Jeffrey Epstein and his associates, including Darren Indyke, Harry Beller, Richard Kahn and Erika Kellerhals. The Treasury Department’s Epstein file also contains details of hundreds of millions in payments to Epstein from Wall Street financiers…”
I want to call your careful attention to the fact that Senator Wyden is using the plural form in his phrase “Wall Street financiers.” Thus far, the only Wall Street financier that has been publicly named for wiring huge sums to Epstein-related accounts is Leon Black, whom Senator Wyden confirms wired $170 million to Epstein’s accounts.
Black is the founder and former CEO of Apollo Global Management, a private-equity firm deeply engaged with Wall Street. Black paid $62.5 million to the U.S. Virgin Islands to resolve its Epstein-related claims against him, including the charge that his money spigot to Epstein helped to keep the sex-trafficking enterprise in operation. Black has been alleged by multiple females to have engaged in sexual abuse including the rape of a minor, the latter allegedly occurring in Epstein’s Manhattan mansion.
If there is a coterie of other Wall Street financiers that are known to the U.S. government to have financed or participated in Jeffrey Epstein’s sex trafficking of underage girls then it’s long past the time for the American people to be made aware of these names and for federal prosecutions to begin in earnest.
If the Justice Department had filed its 60-count indictment against Epstein in 2007 and put him away in prison for the decades-long sentence he deserved, the lives of hundreds of his young future victims would have had a different outcome.
The 11th Circuit Appellate Court reviewed the Justice Department’s handling of the Epstein case and its failure to inform his victims about its sneaky non-prosecution agreement and issued a scathing opinion on April 15, 2021. The court wrote:
“The facts underlying this case, as we understand them, are beyond scandalous—they tell a tale of national disgrace.
“Over the course of eight years, between 1999 and 2007, well-heeled and well-connected financier Jeffrey Epstein and multiple coconspirators sexually abused more than 30 young girls, including Ms. Wild, in Palm Beach, Florida and elsewhere in the United States and abroad. Epstein paid his employees to find girls and deliver them to him—some not yet even 15 years old. Once Epstein had the girls, he either sexually abused them himself, gave them over to be abused by others, or both. Epstein, in turn, paid bounties to some of his victims to recruit others into his ring.”
While the current President of the United States is calling the Epstein matter “a hoax,” attempting to undermine the public’s legitimate outrage and demand for real answers, the Justice Department confirmed in a July 7 memorandum that “…Epstein harmed over one thousand victims. Each suffered unique trauma.”
Other than Leon Black, what the American people do know at this point is that the only other individual to be publicly named as providing vast sums of wealth to Epstein is Leslie Wexner, who is decidedly not a Wall Street financier. Wexner hails from New Albany, Ohio and is the retailing billionaire and former Chairman and CEO of L Brands, which previously owned such retail chains as Abercrombie & Fitch, Victoria’s Secret, Lane Bryant, Bath & Body Works and others. The value of Epstein’s assets originating from Wexner were estimated at over $100 million at the time of Epstein’s death on August 10, 2019.
Joining the mountain of secret documents related to Epstein and his money men that the American people have yet to see are two separate outside counsel investigative reports on Wexner’s dealings with Epstein. In order to get a fuller picture of Wexner’s involvement with Epstein, you will need to obtain those reports.
In 2019, the Board of Directors of L Brands hired the Big Law firm, Davis Polk & Wardwell, to investigate the ties between Epstein and Wexner after their close relationship became public following Epstein’s arrest in 2019 on federal sex trafficking charges. Wexner’s wife, Abigail, had been a lawyer at Davis Polk prior to her marriage to Wexner and the law firm was the longstanding outside counsel to the company. After a shareholder sued L Brands over Davis Polk not having adequate impartiality in the matter, L Brands hired a second law firm, Wachtell, Lipton, Rosen & Katz, to conduct a second investigation.
Although serious outside counsel investigations such as these of publicly-traded companies are typically filed with the SEC and made public, both of these legal reviews of Wexner’s relationship with Epstein remain a dark secret.
In 2023 we filed a Freedom of Information Act (FOIA) request with the SEC to obtain the outside counsel reports conducted by Davis Polk and Wachtell. On August 23, 2023 we received a letter via email from the SEC advising that nothing would be forthcoming to us in the way of documents under our FOIA request. The SEC based its refusal to share relevant information with us on the following:
“We can neither confirm nor deny the existence of any records responsive to your request. Even to acknowledge the existence of such records could interfere with the personal privacy protections provided by FOIA Exemptions…Under Exemption 6 the release of this type of information would constitute a clearly unwarranted invasion of personal privacy….”
Clearly that is a bogus response from a taxpayer-funded federal agency overseeing the integrity of U.S. markets. The firm where Leon Black had worked, Apollo Global Management, had no problem making its Dechert (outside counsel) report public by filing it with the SEC regarding Black’s relationship with and gargantuan payments to Jeffrey Epstein. Senator Wyden has since found that Dechert’s report missed at least $12 million of money flows from Black to Epstein, bringing the current known tally to $170 million.
There is no dispute that Wexner transferred to Epstein the Manhattan mansion where dozens of underage girls have alleged they were raped or sexually assaulted. There is no dispute that a Wexner-related company had previously owned the Boeing 727 that ended up owned by Epstein. It too was alleged to have been the venue for sex trafficking of underage girls.
Virginia Giuffre, one of Epstein’s underage sex slaves who died by suicide in April, gave a deposition under oath in 2016 where she alleged that Epstein had trafficked her for sex to Wexner on multiple occasions. She provided the names of witnesses to the encounters and provided the information to the FBI according to her deposition. And yet the Justice Department’s July 7 memorandum tells us that “We did not uncover evidence that could predicate an investigation against uncharged third parties.”
That statement is as much a “national disgrace” as the Justice Department’s failure to file its 60-count indictment against Epstein in 2007.
The Attorney General’s office for the U.S. Virgin Islands has already built a very strong case against the largest bank in the United States, JPMorgan Chase, that its money laundering for Epstein should be a top priority for criminal prosecution by the U.S. Department of Justice. Its civil complaint against the bank, which JPMorgan Chase paid $75 million to settle in 2023 to avoid a public trial, stated this:
“The investigation revealed that JP Morgan knowingly, negligently, and unlawfully provided and pulled the levers through which recruiters and victims were paid and was indispensable to the operation and concealment of the Epstein trafficking enterprise…JP Morgan facilitated and concealed wire and cash transactions that raised suspicion of—and were in fact part of—a criminal enterprise whose currency was the sexual servitude of dozens of women and girls in and beyond the Virgin Islands. Human trafficking was the principal business of the accounts Epstein maintained at JP Morgan.”
JPMorgan Chase was charged with two felony counts by the Justice Department in 2014 for looking the other way at Bernie Madoff’s obvious money laundering inside the bank. The bank failed to file the mandatory Suspicious Activity Reports with the U.S. (even after telling U.K. regulators that it suspected Madoff was running a Ponzi scheme). Now it turns out that while JPMorgan Chase was facilitating Madoff’s Ponzi scheme impacting thousands of victims, it was simultaneously ignoring Jeffrey Epstein’s money laundering that facilitated sexual assaults on girls as young as 14.
JPMorgan Chase was Epstein’s primary bank, wiring money around the world for him, providing him with hundreds of thousands of dollars in hard cash year after year and giving him a $50 million line of credit according to court filings. JPMorgan Chase held dozens of Epstein-related accounts. We located among court filings an expert report written by a former FBI agent of 23 years, Shaun O’Neill, who indicated in writing that JPMorgan Chase had “impeded” the federal criminal investigation of Epstein.
A major revelation in the document is that former FBI agent O’Neill had been allowed to read the full deposition given in the case by William Langford, an anti-money-laundering (AML) executive at JPMorgan Chase, who had previously worked for the U.S. Treasury’s FinCEN, the agency where SARs are filed.
According to O’Neill, Langford indicated in his deposition that Epstein became a JPMorgan client in 1985, not in 1998, the date that major news media has heretofore reported that the relationship began. If Langford is correct, that would mean that JPMorgan Chase has financial transaction files on Epstein dating back 40 years – which would certainly open a window into who provided Epstein’s early seed money and who his largest financial funders were over the decades.
An internal document filed with the court by JPMorgan Chase lists accounts at the bank that have been coded as “Epstein related” as of October 18, 2007. (See data beginning on page 21 of 29.) Those include accounts belonging to Epstein’s clients (despite a DOJ/FBI joint memo telling the public that no such client list exists.) The table also indicates the date that the account was first opened. An early Epstein-related account is for Leslie Wexner. It was opened on March 9, 2000. A trust for Wexner’s children, of which Epstein was Trustee, was opened on January 21, 1999.
If the House Oversight Committee wants to be taken seriously about its investigation into Epstein’s sex trafficking ring and its financing, it will expand its subpoenas to JPMorgan Chase.
Sincerely,
Investigative Staff at Wall Street On Parade
