EFTA02810827: Jorge Amador’s Report on Epstein’s JPMorgan Accounts and Financial Network
Snapshot
| Item | Details |
|---|---|
| Evidence file | EFTA02810827 |
| Document | Expert Report of Jorge Amador, Axia Advisors, LLC |
| Report date | June 16, 2023 |
| Court filing | Document 238, attachment 31, filed July 25, 2023 |
| Case | Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., Southern District of New York, case 1:22-cv-10904-JSR |
| Length | 161 PDF pages, including an 83 page numbered report and Exhibits A through I |
| Evidence stamps | EFTA02810827 through EFTA02810987 |
| Account network | 134 accounts identified across Epstein, related entities, and associated individuals |
| Central calculation | $78,813,988.99 in transactions Amador classified as unusual and unexpected |
| Separate findings | $25,260,705.30 in direct payments to Ghislaine Maxwell; $102,734,318.53 in transfers to entities classified by Amador as shell companies |
| Evidentiary status | A forensic accountant’s litigation report, supported by cited records. Its opinions are not themselves judicial findings. |
What This Document Is
The Amador report examines how Jeffrey Epstein used JPMorgan accounts to move money through personal accounts, companies, trusts, foundations, aviation entities, and payments benefiting women. Its importance lies in connecting financial records that otherwise appear as isolated transactions.
The report addresses three central questions. What financial activity did Epstein conduct? How did that activity compare with the business purposes recorded for his accounts? What information did JPMorgan possess that could have prompted scrutiny while the transactions were occurring?
The PDF contains bank statement references, transaction summaries, excerpts of internal communications, corporate descriptions, tax record analysis, and supporting exhibits. Many names and substantial portions of the tax discussion are redacted. The visible material therefore supports a detailed reconstruction, but not identification of every recipient or recovery of every underlying transaction.
The court filing date and the report date serve different purposes. June 16, 2023 dates the expert’s work. July 25, 2023 dates this filing. Neither date is the date of the financial activity being examined.
The Author, Method, and Limits
The qualifications and methodology sections, PDF pages 4 through 8, identify Amador as an attorney, certified public accountant, and financial forensics specialist. He describes more than 35 years of accounting experience and work investigating securities disputes and financial records. He discloses compensation of $570 per hour, independent of his conclusions or the litigation’s outcome.
His stated work included tracing the sources and uses of funds, reviewing checks and transfers, comparing bank activity with tax returns, examining due diligence files, and reading internal bank communications. He cites professional forensic accounting standards and federal bank examination guidance as analytical frameworks.
The account group was not created solely from his personal investigation. He states that he relied on counsel’s instructions and JPMorgan’s interrogatory response to identify Epstein related individuals and entities. That matters when interpreting the phrase “Epstein Accounts.” Some accounts belonged to other individuals or their entities. Inclusion does not establish that Epstein owned every account or controlled every transaction.
Amador expressly states that he lacked complete financial records for accounts listed in Exhibit C. He also explains that the report uses examples rather than identifying every relevant transaction. These are limitations of the report itself, not minor omissions in its presentation.
The 134 Account Network
The account inventory, PDF pages 8 through 16 and Exhibit E, divides the identified network into three groups.
| Group | Number reported | Description |
|---|---|---|
| Epstein’s personal accounts | 6 | Accounts identified under Epstein’s name |
| Epstein related entity accounts | 59 | Companies, trusts, foundations, and other entities associated with Epstein |
| Other associated accounts | 69 | Accounts belonging to related individuals and entities associated with those individuals |
| Total | 134 | The combined analytical group used in the report |
The entity inventory includes Financial Trust Company, Southern Trust Company, Southern Financial, Hyperion Air, JEGE, Plan D, NES, the C.O.U.Q. Foundation, Enhanced Education, Butterfly Trust, Haze Trust, Zorro Trust, and Zorro Development Corporation. It also includes property entities and insurance trusts.
The associated individuals discussed include Ghislaine Maxwell, Leslie Wexner, Richard Kahn, Harry Beller, Darren Indyke, and people whose names are redacted. Amador acknowledges that he could not determine the connection for a small number of accounts that JPMorgan identified as related.
The account tables are a map of relationships, not a list of adjudicated participants in trafficking. A victim’s account, an accountant’s account, and an Epstein controlled company account carry different implications.
Why Epstein Mattered Commercially to JPMorgan
The revenue and cash flow discussion, PDF pages 16 through 21, describes Epstein as a commercially significant private banking client. Amador reports more than $8.1 million in bank revenue from Epstein and related entities during 2009 through 2014, the years for which that information was produced.
Internal materials cited in the report placed Epstein eighth in one team’s top client revenue ranking in May 2012. Another June 2013 internal report ranked him second in its client segment, with approximately $1.328 million in revenue for the year to date. These are rankings within the cited business groups, not a claim that he was JPMorgan’s second largest customer worldwide.
The report’s cash flow schedules total $1,037,361,726.01 across the accounts and periods included. It separately identifies $395,343,350.11 in activity for personal account ending 0438. These figures describe account flows. They do not establish Epstein’s net worth, net income, or a billion dollars in unique criminal proceeds. Money transferred among accounts can appear at multiple stages.
Amador also discusses Epstein’s apparent involvement in the Highbridge relationship and a proposed donor advised fund involving prospective major donors. The proposal is evidence of business development efforts, not proof that the contemplated fund was established or received the projected money.
The $78.8 Million Finding
Figure 7, PDF page 27, stamped EFTA02810853, is the central numerical summary. It covers 2003 through 2013.
| Category in Amador’s table | Reported amount | Share of total, rounded |
|---|---|---|
| Cash transactions | $5,040,177.64 | 6.4% |
| Direct payments to women | $3,132,070.88 | 4.0% |
| Indirect payments benefiting women | $500,540.78 | 0.6% |
| Foreign transactions | $15,454,174.11 | 19.6% |
| Legal and litigation expenses | $54,666,918.09 | 69.4% |
| Other payments | $20,107.49 | Less than 0.1% |
| Total | $78,813,988.99 | 100% |
Nearly seven tenths of the total consists of legal and litigation expenses. Consequently, the figure must not be described as $78.8 million paid to victims, spent on sexual abuse, or judicially proven to have been laundered.
Amador’s position is that these transactions warranted scrutiny in the context of Epstein’s conduct, account purposes, and the information available to the bank. That is a different proposition from proving that each transaction funded a crime.
The report separately discusses Maxwell payments, transfers among entities, and wider account flows. Those figures measure different things and must not be added indiscriminately to the $78.8 million.
The Pattern Across the Years
The annual totals in Figure 7 show that the identified activity continued after Epstein’s 2008 conviction and 2009 release from custody.
| Year | Total classified as unusual and unexpected |
|---|---|
| 2003 | $5,192,928.13 |
| 2004 | $6,010,688.54 |
| 2005 | $5,298,520.62 |
| 2006 | $7,321,084.04 |
| 2007 | $9,450,095.53 |
| 2008 | $6,349,698.49 |
| 2009 | $8,366,313.27 |
| 2010 | $18,465,955.59 |
| 2011 | $5,884,652.92 |
| 2012 | $3,983,908.72 |
| 2013 | $2,490,143.14 |
The 2010 peak is primarily explained by $17,460,460.33 in legal expenses that year. It cannot be used as evidence that trafficking payments peaked in 2010.
Cash Withdrawals, Harry Beller, and the Aviation Explanation
The cash analysis, PDF pages 27 through 33 and 63 through 68, describes recurring large withdrawals and checks payable to cash. Harry Beller, Epstein’s accountant, appears repeatedly as the person signing or endorsing checks.
| Account or activity | Amount reported | Context |
|---|---|---|
| Personal account 0438 | $4,351,425.77 | 116 cash withdrawals or checks in the account level table, 2003 through 2011 |
| Personal account 0663 | $90,000 | Three checks for $30,000 each |
| Hyperion account 4332 | $548,751.87 | Checks payable to cash, October 2011 through November 2013 |
| HBRK account 9169 | $27,000 | Cash activity identified between December 2008 and October 2013 |
Amador also identifies occasions when Beller cashed checks from more than one account at the same branch on the same day or around the same date. The report compares bank statements with currency transaction reports and explains why its cash tables do not all show identical totals. They are overlapping presentations, not separate amounts to add together.
A March 2012 internal communication quotes John Duffy describing Epstein’s explanation that the cash paid for fuel abroad. Duffy said he had asked Epstein to withdraw that money from an aviation account. Amador found the explanation insufficiently supported because he did not see receipts substantiating those fuel purchases, while separately documented fuel payments continued from Epstein’s personal account.
The account analysis also records cash activity during Epstein’s incarceration. That warrants examination of who obtained and used the funds. It does not establish the ultimate recipient of every dollar.
Direct Payments to Women
The direct payment schedules, PDF pages 33 through 41 and Exhibit F, identify $3,132,070.88 in payments to women. The tables show recurring amounts and transactions across multiple years, with recipient names extensively redacted.
Amador highlights repeated round amounts and transfers to banks in Russia, Lithuania, and Belarus. Examples include payments through Alfa Bank, VTB Bank, SEB Vilniaus Bankas, and Raiffeisenbank. Some transfer instructions provide no purpose; others refer to replenishing a bank card.
The report uses country level trafficking information as part of its risk assessment. A recipient’s surname, nationality, or bank location does not independently establish trafficking, victim status, recruitment, or wrongdoing. The meaningful questions concern the transaction’s purpose, the relationship between sender and recipient, and corroborating records.
The schedules cannot be converted into a public victim list. A redacted recipient might have been a survivor, employee, associate, intermediary, or someone with another relationship to Epstein. This document does not resolve every identity or role.
Indirect Payments for Education, Healthcare, and Other Expenses
Figures 11 through 13, PDF pages 41 through 45, show that Amador’s indirect payment category extends beyond money deposited directly into women’s accounts.
The category combines $158,958.34 in listed payments benefiting women, $5,600 in related legal payments, and $335,982.44 in payments to associated entities. Together, those figures equal the $500,540.78 in Figure 7.
| Visible provider or institution | Amount shown in the relevant schedule | Context |
|---|---|---|
| Steven D. Kaplan, DMD | $1,260 and $5,700 | Two entries in different redacted beneficiary groupings |
| Pacific College of Oriental Medicine | $21,245.86 | Educational expense listing |
| International Culinary Center | $42,000 | Payment described as benefiting a woman |
| New York Film Academy | $6,040 and $3,500 | Separate beneficiary groupings |
| International Center of Photography | $1,290 | Educational expense listing |
| Fashion Institute of Technology | $2,020 | Educational expense listing |
| ALCC American Language | $1,408 | Language education listing |
| Spanish American Institute | $840 | Educational expense listing |
| Dr. Gerald Imber | $20,000 | Medical expense grouping |
| Dr. Jane Recant | $2,000 | Medical expense grouping |
| Dr. David Price | $412 | Medical expense grouping |
| Alliance Nursing | $2,275 | Medical expense grouping |
| Office Based Surgery Care | $1,500 | Medical expense grouping |
| Samuel C. Klagsbrun, M.D. | $2,000 | Healthcare provider listing |
The Kaplan entries total $6,960. They appear again in the account 0663 discussion on PDF pages 64 and 65. Those later appearances repeat the amounts and must not be counted as additional payments.
These records can establish financial support or payment relationships. They do not, without further evidence, establish a provider’s knowledge of abuse, an improper procedure, or coercion. The tables do not identify Dr. Michael Apa as a payee.
EpsteinWiki’s dental network article provides related context for distinguishing documented dental payments from separate witness allegations.
Payments to Modeling, Publicity, and Associated Businesses
Figure 13, PDF page 45, stamped EFTA02810871, lists the following amounts.
| Entity as visible | Total |
|---|---|
| Redacted entity | $175,000 |
| MC2 Model Management | $26,805.07 |
| Peggy Siegal, Inc. | $32,243 |
| SL Communications and Lifestyle LLC | $27,000 |
| SLK Designs LLC | $74,934.37 |
| Total | $335,982.44 |
The report discusses the entities’ relationships to Epstein and associated individuals. The payments establish financial links as reported in the underlying records. The table alone does not identify what every payment purchased or establish that every business knowingly facilitated trafficking.
A later table for account 0438 lists $320,982.44, including $12,000 for SL Communications and Lifestyle LLC. The difference reflects the narrower account presentation. These two tables should not be added together as independent expenditure totals.
Maxwell’s $25.26 Million and the Helicopter Funding
Figure 15, PDF page 49, stamped EFTA02810875, lists $25,260,705.30 in direct payments to Ghislaine Maxwell. Amador expressly excludes these payments from his $78.8 million calculation.
| Year | Direct payments listed |
|---|---|
| 1999 | $18,300,000 |
| 2002 | $5,000,000 |
| 2003 | $668,037.97 |
| 2004 | $259,867.33 |
| 2005 | $919,050 |
| 2006 | $13,750 |
| 2009 | $100,000 |
| Total | $25,260,705.30 |
The report also traces a separate June 2007 aviation funding sequence. It states that $7.4 million moved from Epstein’s Mellon Bank account into Maxwell’s JPMorgan account, then into Air Ghislaine’s account on the same day. Three days later, $7,352,825 went to Sikorsky Aircraft toward a helicopter purchase.
Those steps describe movement of the same funds through successive accounts. Adding $7.4 million, another $7.4 million, and the Sikorsky payment would exaggerate the underlying funding.
The aviation discussion identifies the helicopter registration as N908GM at the relevant time. Registration history must be read by date because tail numbers and ownership can change.
Foreign Currency Activity
The foreign currency section, PDF pages 49 through 53, identifies 435 transactions across three accounts totaling $15,454,174.11.
| Account | Transactions | Amount |
|---|---|---|
| Epstein account 0438 | 409 | $13,274,535.16 |
| Hyperion account 4332 | 11 | $224,655.79 |
| Epstein account 0663 | 15 | $1,954,983.01 |
| Total | 435 | $15,454,174.11 |
The three displayed account amounts sum to $15,454,173.96, which is 15 cents below the reported aggregate. The table preserves the source figures rather than silently correcting that discrepancy.
Amador discusses purchases of euros and British pounds, transactions near reporting thresholds, and currency transaction reports he expected to find. These are his transaction specific accounting conclusions. The fact that a payment involved foreign currency is not itself proof of a reporting violation or money laundering.
A currency transaction report and a suspicious activity report serve different functions. A bank’s filing of one does not establish that it properly assessed every other risk. Conversely, an allegation about an absent report requires verification against the underlying transaction and reporting requirements.
The $54.67 Million Legal and Litigation Network
Figures 20 and 21, PDF pages 55 through 57, list $54,666,918.09 paid to law firms and other litigation related recipients. Amador acknowledges that legal payments are not inherently suspicious. His concern is their scale and persistence in the surrounding circumstances.
The full payee schedule is reproduced below, preserving partially redacted names. Amounts describe the report’s payee categories, which may include escrow or trust payments rather than fees retained by a lawyer.
| Named recipient | Amount |
|---|---|
| Burman Critton Luttier & Coleman LLP | $17,565,139.01 |
| Darren K. Indyke PLLC | $8,320,000 |
| Alan M. Dershowitz | $4,040,238.40 |
| Black Srebnick Kornspan & Stumpf PA | $3,793,883.25 |
| Gerald B. Lefcourt PC | $3,100,000 |
| Kirkland and Ellis LLP | $2,905,138.12 |
| Partially redacted firm ending Burnett PA | $2,758,921.26 |
| Partially redacted name ending G. Weinberg PC | $2,567,826.71 |
| Darren K. Indyke | $2,448,500 |
| Partially redacted firm ending Tein PL | $1,912,341.07 |
| Atterbury, Goldberger & Weiss, P.A. | $1,802,619.22 |
| Hodge and Francois | $680,810.88 |
| Tonja Haddad PA | $361,280.94 |
| Partially redacted Kellerhals firm | $271,656.93 |
| Partially redacted Steptoe firm | $200,000 |
| Podhurst Orseck P.A. | $163,992.15 |
| Charles D. Barnett, Esq. | $160,000 |
| Nardello and Co LLC | $150,000 |
| Fred Haddad P.A. | $137,500 |
| Troutman Sanders LLP | $114,239.32 |
| Alston & Bird LLP | $106,193.54 |
| Partially redacted Paul Hastings Janofsky firm | $100,000 |
| WHR Investigations Inc. | $97,464.03 |
| Dershowitz, Eiger & Adelson P.C. | $89,011.01 |
| Partially redacted Guthrie McHugh firm | $86,423.98 |
| Partially redacted W. Chester firm | $77,046.57 |
| Marshall Bell Client Escrow | $75,000 |
| Law Office of Guy Fronstin | $73,773 |
| Reeder & Reeder P.A. | $72,804.44 |
| Partially redacted I. Richards P.A. Trust | $70,000 |
| Bruce E. Reinhart PA | $59,234.39 |
| Redacted recipient, Esq. | $50,000 |
| Kreusler Walsh Compiani & Vargas PA | $41,568.71 |
| The LS Law Firm P.A. | $40,091.35 |
| Joel Sickler, sentencing and prisoner advocacy consultant | $25,000 |
| Machado Meyer Sendacz | $24,262.05 |
| Partially redacted Withers firm | $22,157.81 |
| Law Office of Michael Salnick | $15,000 |
| Richard B. Comiter & Associates PA | $15,000 |
| Dudley Topper and Feuerzeig LLP | $11,749.49 |
| Law Office of Samuel Pisar PC | $10,000 |
| Weil, Gotshal & Manges LLP | $9,087.29 |
| Stanley B. Katz, Esq., Escrow Account | $9,000 |
| Barry R. Fertel PC | $7,500 |
| Jonathan Wasserman, PA | $6,600 |
| Partially redacted Longman firm | $5,000 |
| Rubin Katz Law Firm Trust Account | $5,000 |
| Paul Thibadeau, Esq. | $2,696.17 |
| Mehmet Arda Beskardes, Esq. | $2,650 |
| William L. Richey PA | $2,347.80 |
| Partially redacted Lombardi & Olsen firm | $769.20 |
| Law Office of W. Trent Steele | $400 |
Partially redacted names remain incomplete here. The table preserves the distinction between individual payees, law firms, investigators, and accounts holding client money.
The presence of a lawyer or investigator in this schedule is evidence of payment, not proof of participation in abuse, obstruction, blackmail, or trafficking. Determining the purpose requires engagement records, invoices, escrow disbursements, and the relevant case files.
Foundations and Trusts
The C.O.U.Q. analysis, PDF pages 57 and 58 and 68 through 70, identifies $30,362.14 in direct payments to women and two payments to Phoenix Realty Home Inc. totaling $20,107.49. Amador questions their connection to the foundation’s charitable purpose.
| Phoenix Realty payment date | Amount |
|---|---|
| July 24, 2007 | $14,557.49 |
| December 19, 2008 | $5,550 |
| Total | $20,107.49 |
The discussion also refers to a recipient’s account at Banca Transilvania in Iași, Romania. The recipient’s name is redacted in the PDF. The report’s discussion of an alleged coconspirator does not authorize filling that redaction by inference.
The Butterfly Trust table, PDF page 70, stamped EFTA02810896, lists five payments in March and April 2011 totaling $383,000. Individual amounts are $300,000, $25,000, $3,000, $30,000, and $25,000. Recipient names are redacted.
These foundation and trust figures recur within broader analyses. They should not be treated as entirely new amounts outside all previously presented totals.
Financial Trust, Southern Trust, and the Source of Funds
The Financial Trust analysis, PDF pages 71 through 75, challenges whether the documented activity matched the company’s stated financial advisory role. Amador says he did not see the client contracts, invoices, or performance reporting that would substantiate that description in the materials he reviewed.
Figure 35 identifies $178,750,000 transferred from Financial Trust accounts into Epstein’s personal account ending 0438. This is a funding pathway, not an additional category of proven criminal proceeds.
The Southern Trust section, PDF pages 75 through 78, questions the company’s claimed biomedical and financial informatics business. Large portions are redacted, limiting assessment of the tax and financial comparisons.
The visible discussion identifies $158 million from Black as a major source of revenue and refers to the Apollo commissioned Dechert report’s description of tax, estate, philanthropy, and family office advice. Figure 40 separately lists two wires into Southern Trust account 0245.
| Date | Source as displayed | Amount |
|---|---|---|
| February 15, 2013 | Black | $15,000,000 |
| May 24, 2013 | Black | $16,500,000 |
| Total | $31,500,000 |
The two wires are not a complete accounting of the wider $158 million discussed. The report’s criticism concerns whether Southern Trust’s actual activity matched its represented business purpose. These pages do not establish that the payments were blackmail proceeds.
Aircraft, Ownership Entities, and Operating Costs
The aviation section, PDF pages 21 through 25, identifies eight bank accounts, ten entities, and six aircraft in the organizational structure Amador examined.
| Aircraft listed in Figure 6 | Tail number |
|---|---|
| Boeing 727 | N908JE |
| Gulfstream IIB | N909JE |
| Bell 430 | N331JE |
| Bell 407 | N491GM |
| Sikorsky S76 | N722JE |
| Gulfstream G550 | N212JE |
The report describes ownership changes among JEGE, Hyperion, Air Ghislaine, Shmitka Air, Freedom Air International, and Plan D. It also identifies 29 aviation related vendors paid from Epstein’s personal account, including fuel suppliers.
Amador considers the combination of multiple entities and personal payment of operating expenses unnecessarily complex. That is an opinion requiring comparison with legitimate ownership, liability, tax, and operational explanations. Aircraft ownership tables are not passenger manifests and do not establish who traveled on a particular flight.
NES Credit Cards and Personal Spending
The NES analysis and Exhibit I, PDF pages 78 through 80 and 152 through 161, examine corporate credit cards used for travel, retail purchases, lingerie, cosmetics, salons, and spas. The report refers to ten cardholders in a March 2007 internal document, with names partly redacted.
Amador argues that the spending did not match a clear business purpose. He also states that the bank had not completed a Know Your Customer review for the NES account as of September 13, 2013.
Exhibit I presents dated merchant entries across three categories. The lingerie table totals $3,720.89. The cosmetics and spas table totals $11,801.03. The designer store schedule spans five pages. Some entries repeat the same merchant, amount, and date, making the underlying statements important before independently treating every row as a unique charge.
An internal January 2011 message by Maryanne Ryan discusses account activity in the context of known allegations and questions why an associated person had not been subpoenaed. Its evidentiary significance concerns internal awareness. Ordinary purchases of clothes or personal care services do not independently establish sexual conduct, victim status, or criminal participation.
The $102.73 Million Entity Transfer Map
Figure 42, PDF pages 82 and 83, lists 1,423 transfers from account 0438 totaling $102,734,318.53. Amador classifies 31 recipient entities as shell companies and emphasizes repeated transfers, round amounts, and insufficient apparent business purpose.
| Entity as visible in the report | Amount | Transfers |
|---|---|---|
| Cypress Inc. | $122,500 | 2 |
| Forums LLC | $250,000 | 1 |
| Freedom Air Petroleum LLC | $25,000 | 1 |
| FT Real Estate, Inc. | $11,000 | 2 |
| Hyperion Air, Inc. | $2,870,000 | 29 |
| Hyperion Air, LLC | $2,026,000 | 25 |
| I Correct Com LLC | $101,250 | 3 |
| JEGE, Inc. | $11,750,315.62 | 101 |
| JEGE, LLC | $100,000 | 1 |
| Lafayette Contractors, LLC | $2,626,000 | 50 |
| Laurel, Inc. | $150,000 | 1 |
| LCP Company, LLC | $2,666,000 | 93 |
| LSJ, LLC | $32,976,000 | 535 |
| LSJE, LLC | $8,215,000 | 63 |
| Maple, Inc. | $266,000 | 2 |
| Michelles Transportation Co LLC | $95,000 | 5 |
| NA Property Inc. | $22,327.91 | 5 |
| Nautilus Inc. | $150,000 | 3 |
| Neptune LLC | $500,000 | 7 |
| NES, LLC | $23,620,000 | 249 |
| Plan D LLC | $21,000 | 3 |
| Ranch Lake II, Inc. | $450,000 | 8 |
| Ranch Lake III, Inc. | $1,000 | 1 |
| 2001 Jeffrey E. Epstein Insurance Trust | $650,000 | 6 |
| 2007 Jeffrey E. Epstein Insurance Trust 1 | $324,675 | 3 |
| 2007 Jeffrey E. Epstein Insurance Trust 2 | $13,150 | 2 |
| 2007 Jeffrey E. Epstein Insurance Trust 3 | $47,100 | 5 |
| C.O.U.Q. Foundation Inc. | $138,000 | 2 |
| Partially redacted World Air, LLC | $100,000 | 2 |
| Zorro Development Corporation | $11,610,000 | 198 |
| Zorro Trust | $837,000 | 15 |
| Total | $102,734,318.53 | 1,423 |
The classification belongs to Amador. The cited bank descriptions sometimes identify property holding or aircraft operating functions. A company with no employees or separate office can still have a lawful purpose; the issue is whether the particular structure and transactions had a substantiated purpose.
Figure 43, PDF page 84, separately lists $4,945,000 to HBRK Associates, $10,830,000 to New York Strategy Group, and $1,621,655.30 to Maxwell from account 0438. The Maxwell amount overlaps the broader Maxwell payment history and is not an additional independent total.
What Amador Says JPMorgan Could Have Known
The final substantive section, PDF pages 84 and 85, argues that JPMorgan had sufficient information to identify the concerning transactions when they occurred. Amador cites earlier due diligence records, adverse reporting, awareness of large cash withdrawals, and payment patterns.
The report places particular weight on the bank’s knowledge of allegations involving underage girls by 2006 and its continuing access to transaction information. His argument is cumulative: a single withdrawal or invoice might have a lawful explanation, while repeated unexplained activity combined with documented risk information could warrant closer scrutiny.
The July 2013 termination talking points also show that Epstein’s cash activity and personal history were explicitly discussed internally. The report states that the last account in the identified related account group closed March 7, 2014. That does not mean every account remained open until that date.
Several passages about later reporting are redacted. Their contents cannot be reconstructed from surrounding sentences alone.
Challenges to the Analysis and the Case Outcome
An opposing expert filing, Document 290, attachment 7, disputed important parts of Amador’s reasoning. It argued that his revenue measure did not deduct the bank’s costs and that his account complexity analysis failed to adequately consider legitimate liability reasons or comparable clients. These criticisms address the strength of his inferences; they do not automatically negate the listed transactions.
Reuters’ settlement reporting records that JPMorgan agreed to pay $75 million to resolve the Virgin Islands lawsuit in September 2023 without admitting liability. The settlement does not convert every opinion in this report into a judicial finding.
The strongest reading preserves both the documented financial relationships and the distinction between those records, expert interpretation, disputed inference, and adjudicated fact.
Related Sleuth Research
Heather Ashley’s financial network investigation uses the Amador report alongside other records to map companies, trusts, and investments. It is particularly relevant to Southern Financial, Haze Trust, and the broader corporate structure.
That work provides additional research connections. Findings reproduced from Amador remain based on the same underlying report and should not be counted as independent corroboration merely because they appear in a second publication.
Evidence Appearances and Document Map
The complete PDF contains three distinct numbering systems: PDF page number, the report’s printed page number, and the EFTA stamp. Printed report page 1 is PDF page 4. The links below open the parent file; the stamps and page ranges locate the material within it.
| PDF pages | EFTA stamps | Contents |
|---|---|---|
| 1 through 3 | EFTA02810827 through EFTA02810829 | Cover and contents |
| 4 through 8 | EFTA02810830 through EFTA02810834 | Qualifications, data, methodology, opening opinion |
| 8 through 16 | EFTA02810834 through EFTA02810842 | Account network and classifications |
| 16 through 21 | EFTA02810842 through EFTA02810847 | Bank revenue, account flows, business relationships |
| 21 through 25 | EFTA02810847 through EFTA02810851 | Aviation entities, aircraft, vendors, fuel payments |
| 25 through 33 | EFTA02810851 through EFTA02810859 | Aggregate calculation, cash withdrawals, internal communications |
| 33 through 48 | EFTA02810859 through EFTA02810874 | Payments to women, third parties, and associated entities; redacted gift tax material |
| 49 | EFTA02810875 | Maxwell payments and helicopter funding |
| 49 through 53 | EFTA02810875 through EFTA02810879 | Foreign currency transactions |
| 54 through 57 | EFTA02810880 through EFTA02810883 | Legal and litigation expenses |
| 57 through 70 | EFTA02810883 through EFTA02810896 | Foundation payments and individual account analyses |
| 71 through 78 | EFTA02810897 through EFTA02810904 | Financial Trust and Southern Trust |
| 78 through 80 | EFTA02810904 through EFTA02810906 | NES cards and internal bank awareness |
| 81 through 84 | EFTA02810907 through EFTA02810910 | Shell company classifications and transfers |
| 84 through 86 | EFTA02810910 through EFTA02810912 | Contemporaneous detection argument and conclusion |
The Nine Exhibits
Exhibits A through I supply credentials, source inventories, missing record information, and additional schedules. They are integral to understanding how the report was constructed.
| Exhibit | PDF pages | EFTA stamps | Purpose |
|---|---|---|---|
| A | 87 through 89 | EFTA02810913 through EFTA02810915 | Amador’s curriculum vitae |
| B | 90 through 91 | EFTA02810916 through EFTA02810917 | Prior testimony and publication disclosure |
| C | 92 through 95 | EFTA02810918 through EFTA02810921 | Accounts for which financial documents were incomplete |
| D | 96 through 112 | EFTA02810922 through EFTA02810938 | Materials relied upon, including bank records, discovery, tax materials, and public sources |
| E | 113 through 118 | EFTA02810939 through EFTA02810944 | Other associated individuals’ and entities’ JPMorgan accounts |
| F | 119 through 130 | EFTA02810945 through EFTA02810956 | Detailed schedules of payments to women |
| G | 131 through 146 | EFTA02810957 through EFTA02810972 | Aviation database records and registration history |
| H | 147 through 151 | EFTA02810973 through EFTA02810977 | Risk Management Association business comparison material |
| I | 152 through 161 | EFTA02810978 through EFTA02810987 | NES card transactions for lingerie, designer stores, cosmetics, and spas |
Exhibit D is a source inventory, not a complete reproduction of every document it cites. Exhibit C demonstrates why the report cannot be treated as a final accounting of the entire financial network.
Key Takeaways
- The financial schedules connect personal accounts, operating companies, foundations, trusts, aviation entities, and third party expenses in one forensic analysis.
- Figure 7 totals $78.8 million in transactions Amador considered unusual. Most of that amount consists of legal and litigation expenses.
- The Maxwell schedule reports $25.26 million in direct payments outside that central calculation, plus a separately described helicopter funding sequence.
- The entity transfer schedule maps $102.73 million across 1,423 transfers. Repeated movements of funds require care to avoid double counting.
- The internal bank material is central to Amador’s argument that JPMorgan could have recognized concerning patterns earlier.
- The missing record exhibit and visible redactions leave important questions about recipients, purpose, account coverage, and corroboration unresolved.
Questions That Remain
- What do the missing statements listed in Exhibit C add to the account totals and transaction chronology?
- Which underlying checks, wires, invoices, and instructions independently verify each summarized payment?
- Which transfers represent the same funds moving through successive accounts?
- What services or expenses did the payments to healthcare and educational providers actually cover?
- Who ultimately received or spent the cash withdrawn by intermediaries?
- What receipts or other evidence support the explanation that aviation cash paid for fuel abroad?
- How did the bank evaluate repeated cash activity alongside information about Epstein’s abuse?
- What portions of the legal payment total were fees, settlements, retainers, escrow deposits, or later distributions?
- What lawful business purposes and supporting records existed for the entities Amador classified as shell companies?
- What do the unredacted Financial Trust and Southern Trust records show about clients, services, revenue, and costs?
- What account monitoring and internal escalation occurred before termination of the banking relationship?
- Which expert criticisms were answered through additional records, testimony, or revised analysis?
Sources
- EFTA02810827, Expert Report of Jorge Amador. June 16, 2023 report, filed July 25, 2023, Document 238, attachment 31. Primary source for the financial figures, account analysis, communications, and exhibits.
- Justice Department court records for Government of the United States Virgin Islands v. JPMorgan Chase Bank. Case identification and related filings.
- Document 290, attachment 7, opposing expert filing. Criticisms of the revenue and account structure analysis.
- Reuters, JPMorgan settles Epstein lawsuit with US Virgin Islands for $75 million. September 26, 2023 settlement report.
- Heather Ashley, Epstein’s Financial Web. Related sleuth research connecting the report with corporate and financial records.
- EpsteinWiki, Jeffrey Epstein’s Dental Network. Related coverage of dental evidence and payment relationships.