RE: URGENT - Deconfliction request

Hello,

As way of background, there is a civil lawsuit in the Federal District Court for the SDNY against banks based on the banks' provision of financial services to sex offender Jeffrey Epstein. Specifically, an unnamed Epstein victim (and a claimed class of victims, "Doe") are suing both JP Morgan Chase and Deutsche Bank. The government of the U.S. Virgin Islands is separately suing JP Morgan. Both the USVI and JP Morgan are seeking disclosure of the SARs in that matter, and all parties are seeking disclosure in the Doe matters.

FinCEN has been asked to release several SARs related to Epstein. FinCEN expects that initially, just the attorneys representing the banks and the attorneys for the plaintiffs will have access to the SARs. But they anticipate further authorization to disclose the reports to the plaintiffs themselves (i.e., for Deutsche Bank to see the JPMorgan reports and vice versa), and witnesses (e.g., expert witnesses, bank employees) will occurred. Many of the involved SARs referred to transactions that took place over a decade ago, though some of the reports themselves were not filed until roughly a decade later, after Epstein's arrest. Although FinCEN normally does not authorize the disclosure of reports in civil litigation, this litigation presents special circumstances, and the presiding judge has indicated he may order the reports' disclosure if FinCEN does not authorize it.

As a result, FinCEN reached out to the FBI to deconflict. Attached you will find a file with names of individuals and entities referenced in your investigation (NY-3027571). Please review the names and let me know if you object the release of information related to any of the names indicated.

This is an urgent request from FinCEN since they must respond to the judge. Therefore, due to the urgency of the matter, please reply to me by COB 3/29/2023.

Let me know if you have any questions and thanks in advance for your help.

Supervisory Special Agent
FBI FinCEN Liaison Officer
(O) [Redacted]
(M) [Redacted]

EFTA00144244

Hi Seamus,

• Sender: (CID) (FBI)
• Sent: Wednesday, March 29, 2023 4:13 PM
• To: Multiple FBI recipients including (NY) (TFO) PWBYRNE@fbi.gov
• Cc: Multiple FBI recipients
• Subject: FW: URGENT - Deconfliction request
• Context: Email is forwarding 10 additional names from FinCEN for deconfliction, with a response deadline of COB tomorrow, 4/5/2023.
• Sender Role: Supervisory Special Agent, FBI FinCEN Liaison Officer.

Hello,

I am following up on this request. If you need additional time, let me know. If no response is received, we will have to respond, "no objection".

Thank you.

Supervisory Special Agent
FBI FinCEN Liaison Officer
(O)
(M)

EFTA00144243