The Case That Never Saw Daylight
Eighteen thousand concealed emails from Jeffrey Epstein’s Yahoo account have surfaced, revealing a 2007 federal money-laundering probe, as confirmed by records from the Southern District of Florida. These emails provide crucial documentation of the actions of prosecutors, IRS agents, bank officers, and Justice Department officials as they investigated Epstein’s financial activities, exposing the structure and scope of the operation.
The United States Attorney’s Office in Miami initiated the inquiry, using forensic accountants to trace suspicious transfers from Epstein’s Financial Trust Co. to shell entities in the United States Virgin Islands, Cyprus, and Switzerland. Many transactions fell just below reporting thresholds, a tactic known as systematic structuring to avoid detection. This phase mapped the networks behind these transfers.
Agents traced payments through major banks that continued to hold Epstein’s accounts despite compliance warnings. A 2007 analysis described this network as intentionally designed for concealment.
By spring 2007, investigators identified six businesses controlled by Epstein, including JEGE LLC, Southern Trust Company, and NES LLC, processing transactions unrelated to their stated activities. Several were established by trust managers previously connected to private equity funds serving Epstein’s high-profile clients, such as financiers and political donors implicated in the network.
During this period, subpoenas were issued to offshore banks. In response, senior officials narrowed the scope of requests and restricted interagency communication. One directive instructed staff to keep trafficking crimes and financial probes separate, isolating the money-laundering investigation.
By mid-2007, investigators had unraveled at least twenty million dollars in dubious transfers between Epstein’s entities and the private accounts of his distant associates, stretching from Europe to the Middle East. The inquiry, now running on hope and determination, slammed to a halt after senior officials reviewed the evidence and abruptly shrank its scope. They justified this as a question of jurisdiction and resources, but to agents whose mission had been abruptly sabotaged, these were hollow words. Nearly a quarter of the task force was torn away, and ten subpoenas were left to wither, silencing crucial leads. In a single stroke, 40% of the money trail vanished into darkness. Once urgent correspondence was reduced to info-only memos, the investigation, so close to the heart of Epstein’s network, was suddenly cold.
While the trafficking inquiry focused on victims, the financial branch exposed the intricate web of banks, shell companies, and intermediaries that enabled, protected, and profited from abuse. This investigation revealed how Epstein’s wealth was systematically converted into influence, making these financial channels critical to amplifying his power and connecting the abuse with the underlying financial mechanisms.
Ultimately, the money-laundering case nearly exposed Epstein’s financial network before it was halted. This abrupt end marked a turning point in the investigation, changing its direction.
The Villafaña Draft.
Assistant U.S. Attorney Marie Villafaña led the financial inquiry in the Southern District of Florida. As a career prosecutor with expertise in financial crime and asset forfeiture, she recognized early that Epstein’s payments to victims and intermediaries were part of a complex laundering scheme that disguised criminal proceeds as legitimate transfers.
Recovered correspondence shows that in February 2007, Villafaña began compiling financial data from Epstein’s companies and personal accounts. She issued subpoenas targeting Financial Trust Co., Southern Trust Company, JEGE LLC, NES LLC, and associated accounts previously flagged for irregular activity.
The data revealed a coordinated pattern of large cash withdrawals and international wire transfers executed by Epstein’s assistants, including Sarah Kellen, Lesley Groff, and Adriana Ross. Funds were distributed to women and recruiters in the United States, the United Kingdom, France, and the Dominican Republic. Several transfers corresponded with known victim travel dates, while others moved through offshore accounts registered to charitable fronts such as the Enhanced Education Fund and the C.O.U.Q. Foundation. According to subsequent Deutsche Bank compliance reports, many of these payments lacked legitimate business justification and were classified as “personal disbursements.” Several transactions were routed through correspondent banks in Luxembourg and Switzerland, concealing both the intermediaries and the final recipients.
By mid-2007, Villafaña compiled a prosecution file, including an eighty-two-page memo on anti-money-laundering violations and a draft fifty-three-page indictment naming Epstein, supported by transaction records and witness statements.
Villafaña’s memorandum described Epstein’s operation as merging personal trafficking with corporate laundering, concealing illicit funds as legitimate activity. She called for swift action to preserve assets and evidence.
Senior officials in the U.S. Attorney’s Office overruled her. Internal emails from March and April 2007 show that Villafaña’s requests for expanded subpoenas were “revised for scope” after review by supervisory attorneys, who instructed her to “limit the exposure of ancillary institutions.” In one exchange preserved in the recovered cache, a deputy chief wrote, “Coordination with IRS-CI [Criminal Investigation Division] is not authorized at this stage. Maintain within office.”
This pattern was later confirmed during interviews conducted by the Department of Justice’s Office of Professional Responsibility (OPR) as part of its 2020 internal review. Former Southern District of Florida prosecutors Jeffrey Sloman, Matthew Menchel, and Alicia Valle each told OPR investigators that Villafaña’s financial inquiries were curtailed by senior leadership. Menchel said she was viewed as “too aggressive for Main Justice’s comfort,” while Sloman stated that leadership “wanted the matter managed quietly.” Valle corroborated that her proposal to coordinate with the IRS Criminal Investigation Division “was not authorized by leadership.”
The prosecution memo and draft indictment remained sealed, showing that by 2007, federal authorities had detailed evidence but still ended the only probe capable of exposing Epstein’s financial network.
Wexner, the Financier, and the Fallout
In August 2007, Assistant U.S. Attorney Marie Villafaña contacted Les Wexner, L Brands founder and Epstein’s longest-serving financial client. Epstein had managed Wexner’s fortune for over fifteen years, retaining signatory authority on his trusts and foundations.
According to internal Justice Department correspondence, Villafaña requested Wexner’s records to clarify Epstein’s role in investment decisions, international transfers, and family trust structures moving capital through multiple jurisdictions. She also sought documentation of Epstein’s travel and access to Wexner-related corporate accounts.
Epstein’s legal team responded immediately. Within forty-eight hours, they filed objections through the U.S. Attorney’s Office, accusing prosecutors of harming Epstein’s business reputation and targeting his professional relationships. Recovered emails show Epstein’s lawyers warned that further contact with Wexner would be considered contract interference.
Despite the pushback, Villafaña’s office continued the inquiry. Two investigators were assigned to review Epstein’s management of Wexner’s real estate portfolio, which included properties in New Albany, Manhattan, and the Virgin Islands. Notes from those agents indicate that Epstein maintained control over liquid assets and property titles long after Wexner’s accountants claimed he had relinquished authority.
Weeks after Villafaña’s outreach, Wexner severed formal ties with Epstein. Corporate filings show the revocation of Epstein’s power of attorney and his removal from two private entities managing L Brands’ investments. Advisers transferred management to an Ohio-based firm specializing in asset restructuring.
Neither Wexner nor his advisers publicly explained the split. The timing, which coincided with the federal probe, suggests Villafaña’s request was the first official attempt to scrutinize Epstein’s client relationships. Correspondence shows investigators knew Epstein managed a major U.S. retail fortune. The end of his relationship with Wexner shifted the investigation’s focus to broader corporate and political connections.
The Acosta Contradiction
Recovered emails show Alex Acosta, then U.S. Attorney for the Southern District of Florida, was directly included in internal communications about the ongoing money-laundering investigation into Jeffrey Epstein. These messages, verified through the Southern District archive, indicate Acosta received updates circulated among prosecutors and investigators in 2007 and early 2008.
Three email threads from March to November 2007 show Acosta receiving detailed updates from Villafaña about subpoenas, grand-jury requests, and communications with Epstein’s legal team. One thread references bank record subpoenas and a proposed FinCEN request, while another includes draft internal memo language on potential money laundering offenses.
In one message to senior staff, a deputy in the U.S. Attorney’s Office summarized Villafaña’s findings and wrote that the “financial side could open further exposure at the institutional level.” Acosta was among the recipients. Follow-up correspondence indicates that Villafaña’s proposed subpoenas were “revised for scope” after review by supervisory attorneys, a decision that narrowed the investigation to personal conduct rather than financial networks.
When questioned before Congress in 2025 about any financial dimension to the Epstein case, Acosta stated that he “did not recall” such an inquiry and maintained that his office “was focused on the inappropriate acts that took place in Palm Beach.” Hearing transcripts show he denied knowledge of any money-laundering component, despite documented evidence of his inclusion in the correspondence chain. The inconsistency between Acosta’s testimony and the recovered records suggests that elements within the Justice Department minimized or suppressed financial evidence that could have linked Epstein’s operation to major banks, hedge-fund partners, political donors, and corporate intermediaries.
The same U.S. Attorney who received those financial updates would later personally negotiate and approve Epstein’s 2008 non-prosecution agreement, a deal that granted Epstein immunity from federal charges and extended protection to “any potential co-conspirators.” Internal DOJ communications reviewed by investigators show that the agreement was structured to foreclose further federal inquiry, including the money-laundering and asset-forfeiture components that Villafaña’s team had developed. Acosta defended the decision as a “global resolution,” though the terms effectively dismantled the only federal case capable of exposing the network that financed Epstein’s operation.
The timing of the narrowed communications suggests that senior officials acted to protect institutional and political relationships linked to the case. According to the Department of Justice’s Office of Professional Responsibility (OPR) interviews, supervisory attorneys in the Southern District of Florida and officials in Main Justice’s Criminal Division expressed concern that a broader financial investigation could “complicate resolution” and “create exposure for entities beyond the immediate subject.” Internal correspondence reviewed by Bloomberg and the DOJ Inspector General indicates that prosecutors were directed to maintain focus on “the Palm Beach conduct” to prevent “unnecessary expansion into financial channels.”
In practice, this meant shielding the banks, fiduciaries, and private foundations that had serviced Epstein’s accounts from subpoena scrutiny. The Department’s public framing of the case as a local sex-crimes prosecution allowed officials to resolve it without implicating corporate or political intermediaries.
Acosta’s later claim of ignorance during congressional testimony aligns with these internal priorities. His denial was not simply a lapse of memory but a continuation of the Department’s strategy to separate Epstein’s criminal behavior from the financial system that enabled it. By omitting the money-laundering probe from public narratives, Justice Department leadership preserved the appearance of a self-contained case while concealing the infrastructure of wealth, influence, and institutional complicity that sustained it.
The Banks That Stayed
Internal compliance documents reviewed by Spooky Connections show that major U.S. and European banks continued to support Jeffrey Epstein’s financial network long after his 2008 conviction. Despite extensive risk warnings and repeated internal filings, JPMorgan Chase, Deutsche Bank, and other institutions provided Epstein with private banking services, investment facilities, and international transfer capabilities, enabling him to move millions with minimal scrutiny. Notably, JPMorgan Chase processed over $1 billion in transactions through Epstein-linked accounts between 2008 and 2013. For context, the typical compliance threshold for scrutinizing high-risk clients involves rigorous reviews for much lower amounts, indicating a willful blindness to the red flags that should have prompted further investigation.
At JPMorgan Chase, internal Suspicious Activity Reports (SARs) were filed as early as 2002, highlighting patterns of large cash withdrawals and payments to individuals overseas. After Epstein’s 2008 conviction for procuring minors, compliance officers renewed their concerns, citing reputational risk and possible structuring violations. Executive leadership overruled these warnings, classifying Epstein as a “high-value client” and noting that his connections in finance and politics were “strategic.” In one internal communication, a senior executive stated that the relationship was “managed at the chairman’s level.”
Between 2008 and 2013, JPMorgan processed over $1 billion in transactions through Epstein-linked accounts. Several transfers passed through intermediary firms in the U.S. Virgin Islands and Switzerland. Although the bank’s automated monitoring systems triggered repeated alerts, compliance personnel were instructed to “review manually” and “clear with discretion.” In 2023, a lawsuit by the U.S. Virgin Islands government produced emails confirming that top executives, including former asset-management head Mary Erdoes and former investment chief Jes Staley, received multiple internal risk memos referencing Epstein’s criminal record and ongoing activity.
Deutsche Bank took over Epstein’s accounts in 2013, despite knowing JPMorgan had ended the relationship for compliance reasons. Internal audit documents show that Deutsche Bank relationship managers approved more than 120 international wire transfers totaling over $7 million between 2013 and 2018, many to recipients with no verifiable connection to legitimate business operations. These transactions included payments to women linked to Epstein’s inner circle and to organizations registered in Eastern Europe and the Caribbean.
In 2020, the New York State Department of Financial Services fined Deutsche Bank $150 million for “significant compliance failures” related to its dealings with Epstein. The regulator’s report cited evidence that staff repeatedly ignored automated alerts and compliance officers’ warnings. One internal message described Epstein as “very sensitive, handled by management only.” Despite the fine, no Deutsche Bank executive was charged or sanctioned, and the bank referred to the lapses as “historical errors.”
Offshore trusts and charitable foundations connected to Epstein, including the C.O.U.Q. Foundation, the Enhanced Education Fund, and entities registered in the Virgin Islands, continued to operate through these banks, enabling Epstein to shift assets and obscure beneficiaries well into the final years of his life. These structures also facilitated payments to associates and continued to generate returns through hedge-fund placements managed by partners in New York and London.
Together, the financial institutions, offshore vehicles, and private foundations created a structure that insulated Epstein’s network from meaningful oversight. Financial activity continued long after his arrest, conviction, and death. The system that enabled his crimes did not collapse with him; it adapted and persisted. For instance, in 2019, a year after Epstein’s death, a transaction involving a shell company linked to Epstein transferred substantial funds to a Luxembourg-based trust. Despite its suspicious origins, the transfer went unchallenged, highlighting how financial channels quickly absorbed and repurposed his wealth. This anecdote underlines the resilience of the network, where mechanisms in place continued to facilitate and obscure financial flows, demonstrating that the infrastructure supporting Epstein’s operations adapted to sustain its existence even as individual actors were removed.
Recent investigations confirm that portions of this infrastructure remain active under different ownership and management. Unsealed court filings in late 2025 revealed that Epstein maintained accounts with Goldman Sachs and HSBC, and that posthumous transactions involving these institutions triggered Suspicious Activity Reports filed by JPMorgan Chase.¹ New civil suits filed in October 2025 accuse Bank of America and Bank of New York Mellon of knowingly providing financial services that enabled Epstein’s trafficking operation and of failing to report suspicious transactions as required under federal law.²
In parallel, the U.S. Senate Committee on Finance continues to investigate Epstein-related banking irregularities, pressing JPMorgan executives to explain why compliance warnings were ignored. The committee’s October 2025 statement criticized the bank’s response as “evasive” and noted that internal correspondence still withheld by the institution may reveal “systemic failures to enforce anti–money laundering obligations.
The Expert Who Saw What Was Missed
In Bloomberg’s FOIA Files investigation published in October 2025, Stefan Cassella, former Deputy Chief of the Department of Justice’s Asset Forfeiture and Money Laundering Section, provided one of the clearest explanations of what the abandoned Epstein financial case could have revealed. Cassella, who spent more than two decades overseeing federal prosecutions of complex laundering operations, examined the documentation from the 18,000-email archive and confirmed that prosecutors in 2007 already had the legal tools to dismantle Epstein’s financial network if allowed to proceed.
Cassella explained that a full prosecution under 18 U.S.C. sections 981, 982, and 1956 would have enabled the Justice Department to trace, seize, and forfeit assets tied to criminal conduct, while compelling testimony from bank executives, fiduciaries, and trust managers who handled Epstein’s money. These powers could have required cooperation from both domestic and foreign institutions that serviced Epstein’s accounts, obliging them to identify counterparties, beneficiaries, and intermediaries.
“The records show this was not only about individual payments,” Cassella told Bloomberg. “It was about a pattern of money flows consistent with the concealment of criminal proceeds. Following those transfers could have identified other individuals and institutions that facilitated his sex-trafficking operation.”
The emails and related grand-jury material reviewed by Bloomberg show that federal investigators had already flagged multiple accounts controlled by Epstein through shell companies in the U.S. Virgin Islands, Switzerland, and the United Kingdom. These accounts interacted with private equity funds, hedge-fund structures, and charitable foundations linked to known associates. Cassella described the financial data as “a map of the ecosystem” supporting Epstein’s activities and protecting the flow of illicit money through legitimate markets.
Had the investigation continued, prosecutors could have issued forfeiture subpoenas to pierce the secrecy of corporate jurisdictions such as Luxembourg, Liechtenstein, and the Channel Islands. Those subpoenas would have compelled disclosure of trust registries, nominee directors, and client lists associated with Epstein’s offshore holdings. According to Cassella, the case could have exposed a network of financial service providers who knowingly facilitated the concealment and movement of criminal proceeds.
The investigation was halted in 2008 when Epstein’s state-level plea agreement was finalized. Cassella described that decision as “a forfeiture failure of historic scale,” because the closure removed the federal government’s ability to compel records from international banks and to recover funds derived from exploitation. By some estimates, the government forfeited the chance to recover potentially hundreds of millions of dollars in assets connected to Epstein’s network. This included funds laundered through corporate entities and offshore accounts, assets that could have been seized to provide restitution to victims and aid ongoing investigations into other co-conspirators. Once jurisdiction shifted to the state level, the financial trail effectively went dark.
“The decision to end the financial case erased the trail that connected Epstein’s personal conduct to institutional complicity,” Cassella said. “It was the only route that could have produced a complete accounting of who enabled him and how the system worked.”
By closing the money-laundering probe, the Justice Department preserved the boundary between Epstein’s individual crimes and the financial structures that sustained them. Evidence reviewed by Bloomberg shows the government knew in 2007 that Epstein’s abuse was inseparable from his financial network and chose not to follow the money.
A System Built to Protect Itself
From Marie Villafaña’s blocked indictment to Alex Acosta’s selective memory, the documentary record shows a consistent institutional pattern: suppression of evidence, containment of exposure, and preservation of financial and political privilege. The federal money-laundering probe, active from 2007 to 2008, was the first investigation to connect Epstein’s trafficking operation to a network of banks, private equity firms, and offshore service providers managing his assets. Its findings could have shifted the case from an individual criminal matter to one implicating a global network of influential individuals and institutions.
Villafaña’s draft indictment, sealed before it could reach a grand jury, detailed the mechanisms by which Epstein’s wealth was generated and circulated. Her memorandum described transactions linking JPMorgan Chase, Deutsche Bank, and First Republic Bank to trust entities registered in the U.S. Virgin Islands, Luxembourg, and Switzerland. It outlined how foundations such as the C.O.U.Q. Foundation and the Enhanced Education Fund functioned as conduits for laundering payments that were, in reality, disbursements to recruiters, assistants, and victims.
The draft also identified intermediary firms that provided administrative support to Epstein’s accounts, including private wealth offices in New York and London. According to recovered DOJ correspondence, these intermediaries acted as “firewalls” between Epstein’s transactions and the institutions executing them. Such arrangements were common in the shadow-banking sector, where risk was outsourced through layers of shell companies and trustees.
Once the financial component of the case was suppressed, the Justice Department’s narrative focused solely on the Palm Beach victims, excluding the economic system that financed and concealed the crimes. This shift protected the banks and fiduciaries whose compliance departments had filed internal Suspicious Activity Reports. It also shielded politically connected clients named in subpoena drafts, many of whom maintained relationships with Epstein after his conviction.
Alex Acosta’s later testimony before Congress, in which he claimed not to recall any financial aspect of the Epstein case, reflected the institutional amnesia that followed. Internal records show he was copied on multiple emails discussing financial subpoenas and asset forfeiture options. By minimizing the money-laundering dimension, Acosta maintained the separation between Epstein’s personal conduct and the corporate mechanisms that supported it.
Within the Justice Department, this approach became policy. Investigators were instructed to compartmentalize the trafficking and financial divisions, ensuring that evidence of systemic complicity remained siloed. The grand-jury materials were never unsealed, and all related exhibits were archived under restricted access, classified as “non-releasable investigatory material.”
The consequences were significant. The failure to pursue the financial investigation allowed the institutions managing Epstein’s wealth to continue operating without scrutiny. Banks that serviced his accounts retained senior leadership, and fiduciaries who handled his offshore assets continued to manage other politically sensitive clients.
In practical terms, the US federal government prioritized the interests of the wealthy and powerful over accountability. The investigation that could have exposed the structure of Epstein’s power, where money, influence, and exploitation intersected, was halted, allowing the broader system to remain intact.
The network that trafficked children and women relied on more than secrecy and violence. It depended on liquidity, compliance departments willing to overlook irregularities, and political offices prepared to intervene. Epstein’s power was not unique; it reflected a system that enabled and protected him. When the investigation was sealed, the institutions remained intact and the criminal network unaddressed. Epstein was prosecuted, but the systems that enabled his activities continue to operate. To dismantle this persistent network, it is critical for legislators, regulators, and the public to push for stronger oversight and transparency in financial transactions. Implementing mandatory anti-money laundering checks and audits in financial institutions, alongside enforcing stricter penalties for non-compliance, could prevent the perpetuation of such networks. This is not just a call to action but a necessity to ensure that justice extends beyond individual accountability and addresses the systemic issues that allow such criminal operations to thrive.
- Bloomberg News. “Jeffrey Epstein Was Subject of Money-Laundering Probe.” Bloomberg, October 31, 2025.
- New York State Department of Financial Services. Consent Order Under New York Banking Law § 44: In the Matter of Deutsche Bank AG, File No. 2020-009-E (July 7, 2020).
- Bloomberg News. “Epstein’s Emails Reveal Money Laundering Probe in Sex Trafficking Case.” Bloomberg Features, October 31, 2025.
- Reuters. “Jeffrey Epstein Had Accounts with Goldman Sachs and HSBC, Documents Show.” Reuters, November 4, 2025.
- Business Insider. “Epstein Victim Lawsuits Against Bank of America and BNY Mellon Fast-Tracked for 2026.” Business Insider, October 2025.
- Wyden, Ron. “With JPMorgan Chase Dodging Epstein Inquiry, Wyden Investigation Drills Down on Bank Executives’ Unexplained Conduct.” U.S. Senate Committee on Finance, October 20, 2025.
- U.S. Department of Justice, Office of Professional Responsibility. Report of Investigation Regarding the United States Attorney’s Office for the Southern District of Florida’s Resolution of the Federal Investigation into Jeffrey Epstein (Washington, D.C.: Department of Justice, November 2020).

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