EFTA01648787: Suspicious Activity Report Excerpts
Snapshot
| Record | EFTA01648787, a two-page compilation of excerpts under three Suspicious Activity Report (SAR) numbers. |
|---|---|
| Pages | EFTA01648787 and EFTA01648788, the printed identifiers on PDF pages 1 and 2. |
| Identified institutions | JPMorgan Chase Bank N.A. and JPMorgan Securities LLC in the first excerpt; UBS Financial Services Inc. in the third. The middle excerpt does not identify its filing institution. |
| Reported periods | October 1, 2003 through July 22, 2019; November 12, 2019 through July 9, 2020, and December 18, 2014 through July 10, 2020. These are activity periods, not stated filing dates. |
| Document date | The compilation supplies no overall preparation date, author or cover sheet. The underlying SAR filing dates are not printed in these excerpts. |
| Evidence limits | The excerpts record suspicions and aggregate transaction scopes. They include no transaction ledger, supporting bank statements, subject responses or judicial determination of the reported activity. |
Key Takeaways
- The JPMorgan excerpt reports 4,725 wire transactions totaling $1,081,819,653 across a long list of people and entities. That total is not an amount attributed to any single person or organization.
- The middle excerpt reports $17,883,176.30 in suspicious activity and explicitly says the origin of the funds is unknown. Its suggested connection to human trafficking is an allegation in the excerpt.
- The UBS excerpt reports 29 payments totaling $18,289,739.65, comprising three credits and 26 debits. The combined figure is not a net transfer to one recipient.
- The three report numbers identify separate excerpts with different coverage periods. The compilation does not establish whether their transactions overlap, so their amounts cannot be treated as a verified combined total.
- The SAR narratives do not establish criminal conduct by every named person or show how any investigation of these particular transfers was resolved.
What the document contains
EFTA01648787 begins with a narrative headed SAR 31000154806804, naming JPMorgan Chase Bank N.A. and JPMorgan Securities LLC as the reporting institutions. The next heading, SAR 31000171404867, appears near the bottom of page 1. Its text begins with a conclusion on page 2. A third heading, SAR 31000174054068, introduces the UBS Financial Services narrative on that same page.
The two-page file therefore preserves selected narrative passages rather than three complete SAR forms. It does not show the underlying reports’ full subject fields, filing histories, transaction schedules or attachments. The printed EFTA numbers identify pages in this compilation; the longer numbers following SAR identify the reports quoted within it.
The three reported scopes
The first page and second page supply the following report-level figures. No per-person or per-entity allocation appears in the compilation.
| SAR number | Reporting institution | Activity period | Count and type | Reported aggregate |
|---|---|---|---|---|
| 31000154806804 | JPMorgan Chase Bank N.A. and JPMorgan Securities LLC | October 1, 2003 through July 22, 2019 | 4,725 wire transactions | $1,081,819,653 |
| 31000171404867 | Not identified in the excerpt | November 12, 2019 through July 9, 2020 | Count not provided | $17,883,176.30 |
| 31000174054068 | UBS Financial Services Inc. | December 18, 2014 through July 10, 2020 | 29 payments: 3 credits and 26 debits | $18,289,739.65 |
The reported amounts describe activity reviewed by the respective filers. They do not establish the amount of criminal proceeds, an individual’s wealth, a victim’s loss or the value of a particular property. Because the file provides no transaction-level reconciliation, it cannot show whether the same funds were counted in more than one report.
JPMorgan: a broad review of wire activity
SAR 31000154806804 describes activity involving current customers, former customers and people or entities that were not JPMorgan customers. Jeffrey Epstein and Ghislaine Maxwell appear among many named individuals, companies, foundations and trusts; other names are redacted. Inclusion in that list does not establish that every listed party held a JPMorgan account or had the same role in the reported activity.
The narrative’s stated reasons for reporting include adverse media about alleged sex trafficking of minors and allegations that Epstein misappropriated money while working as a money manager. It also cites use of multiple accounts, the Russian Federation as a high-risk jurisdiction and Epstein’s status as a politically exposed person because of his relationships with two U.S. presidents. These are the institutions’ stated risk considerations, not findings supplied by the compilation.
The excerpt contains no individual wire dates, counterparties, amounts or explanations matched to each listed subject. It cannot support assigning the $1,081,819,653 aggregate to a particular foundation, trust, adviser, family or other person in the list. It also does not identify which transactions prompted each of the stated concerns.
The unidentified filer: a conclusion about the origin of funds
The conclusion under SAR 31000171404867 describes transfers that the writer believed appeared intended to conceal the origin of money used for a property purchase, daily living expenses and legal defense fees for a person indicted for sex trafficking crimes. The passage says the origin of the money is unknown and suggests that it may have come from human trafficking proceeds.
The passage further describes transfers through an individual’s and a business’s accounts that the writer believed could conceal a connection to a partially redacted name beginning with Ghislaine. It reports activity from November 12, 2019 through July 9, 2020 totaling $17,883,176.30. The excerpt does not identify the individual, business, property, account numbers or specific transfers underlying that total.
The word “Conclusion” labels the quoted report passage; it does not turn the allegation into a court finding. Neither the reporting institution nor the supporting analysis is identified in these two pages. The uncertainty expressly stated about the origin of the money remains unresolved within this document.
UBS: suspected asset concealment and external accounts
SAR 31000174054068 states UBS Financial Services’ suspicion that Ghislaine Maxwell may have attempted to hide assets from federal courts through UBS accounts and wires to external accounts held or controlled by Scott Borgerson. The narrative describes Borgerson as a trustee on several Maxwell UBS trust accounts. These statements describe the bank’s suspicions and account associations; the excerpt provides no adjudication that Borgerson or Maxwell committed an offense through the reported transfers.
The UBS narrative also refers to contemporary media reporting about a possible marital relationship. That reference is not independent proof of marital status or a substitute for the trust and account documents. The source contains redacted portions of names, which remain redacted in the preserved PDF.
UBS reports 29 payments, specifically three credits and 26 debits, involving Maxwell’s UBS accounts and external bank accounts associated with Borgerson. Its $18,289,739.65 total covers December 18, 2014 through July 10, 2020. The excerpt does not give a credit total, debit total, net flow, individual payment amounts or a recipient-by-recipient breakdown. It therefore does not establish that Borgerson personally received that whole amount.
Responses and unresolved questions
The compilation itself contains no response from Maxwell, Borgerson or other listed people. It also contains no later correction, prosecutorial decision or court ruling resolving the suspicions in the three excerpts.
In a separate December 14, 2020 bail memorandum, Maxwell’s lawyers argued that she had no undisclosed wealth, was not hiding assets overseas and had made accurate financial disclosures. That defense submission was an argument in support of bail, not a ruling on the suspicions summarized here or a direct response to this SAR excerpt.
Reuters reported on March 27, 2026 on Maxwell’s UBS dealings and an untitled, undated document summarizing SARs. UBS declined to discuss Maxwell or Reuters’ payment questions, saying it does not discuss client-related matters. Reuters reported that a prison spokesperson said Maxwell would not comment, attorney David Oscar Markus declined comment, and Borgerson did not respond. These reported responses to Reuters’ broader inquiry neither confirm nor refute the specific allegations in this excerpt.
The missing underlying records matter to the interpretation of the figures. The complete SARs, transaction schedules, account documentation and any subsequent investigative or judicial records would be needed to establish the path and purpose of individual payments. The two-page compilation alone does not resolve those questions.
Evidence Appearances
The source PDF contains two printed EFTA page identifiers and three SAR headings. The middle report crosses the page break.
| Evidence ID | PDF page | Contents and significance |
|---|---|---|
| EFTA01648787 | 1 | SAR 31000154806804: JPMorgan institutional introduction, transaction count and total, activity period, subject list with redactions, and stated reporting concerns. The page ends with the heading SAR 31000171404867. |
| EFTA01648788 | 2 | Conclusion for SAR 31000171404867, with an unknown source of funds, alleged concealment rationale, period and total. SAR 31000174054068 follows with the UBS suspicion, account associations, 29-payment count, credit/debit split, period and total. |
Redactions and evidentiary limits
The redacted source does not identify every person or explain every account relationship. Text concealed by black bars is not available in this source. A person’s inclusion in a reporting narrative does not, by itself, establish wrongdoing, and the excerpt does not assign equivalent knowledge or conduct to everyone listed.
The compilation is useful for identifying what the reporting narratives said, the periods they covered and the aggregate figures they recorded. Its limits are equally concrete: incomplete underlying reports, no transaction ledger, no disclosed basis for assigning amounts to individual subjects, no reconciliation between reports and no outcome for the particular suspicions described.
Sources
- EFTA01648787, site-hosted two-page PDF. Printed page identifiers EFTA01648787 and EFTA01648788. Excerpts headed SAR 31000154806804, SAR 31000171404867 and SAR 31000174054068. This is the source for the document description, reported figures and attributed suspicions.
- Reuters, report on Maxwell’s UBS dealings, March 27, 2026, republished by Investing.com. Used for the later response context only; the SAR figures and payment directions above are taken directly from the PDF.
- United States v. Ghislaine Maxwell, defense memorandum supporting renewed bail, No. 20-cr-330, Document 97, filed December 14, 2020. Section B, printed pages 15 through 18 (PDF pages 21 through 24), particularly printed pages 17 and 18. Used for the defense position on financial disclosure, not as a judicial finding.