A U.S. Virgin Islands investigation into the financial affairs of Jeffrey Epstein has progressed into a sprawling financial probe in recent months, with law enforcement issuing dozens of subpoenas to more than 65 corporate and financial entities around the world and lawyers for Epstein’s estate formally petitioning a judge to reclassify the investigation as “complex,” a move that would shift it to a different legal division. Creatures of the Swamp can report that U.S.V.I. officials, relying primarily on a civil R.I.C.O. statute traditionally used against organized crime affiliates, have filed a second amended complaint against Epstein’s Estate, as well as one of its representatives, attorney Richard Kahn, in his individual capacity as well as in his capacity as the Estate’s representative.

The new complaint charges the “Epstein Enterprise” with more than two dozen claims of facilitating criminal activity, including sex trafficking, abuse of minors, forced marriages, movement of illicit money, and a massive tax fraud scheme that the Government claims resulted in Epstein hiding $80 million from tax officials. Kahn, who has represented the Epstein Estate in various respects, denies his involvement in Epstein’s schemes, but now stands accused of helping facilitate immigration visa violations and sham marriages to help Epstein with transport of victims.

The ongoing investigation, which began in January 2020, has slowly but significantly expanded since its inception. An initial batch of subpoenas to hedge funds, banks, and art holding companies appeared crafted to give law enforcement a firmer understanding of Epstein’s assets and the structure of his massive corporate network. But in the months since those first subpoenas, records show that investigators have shifted focus to high-profile Epstein associates and corporate entities that may be connected to his criminal enterprises, like sex trafficking and money laundering.

U.S.V.I. investigators have repeatedly sought information from Leon Black, former CEO of major U.S. hedge fund Apollo Global Management. Black recently resigned as a result of negative backlash over his extensive relationship with Epstein. An internal investigation revealed Black paid Epstein $158 million for “tax advice” and estate planning services. In January, after the internal investigation concluded the Apollo CEO was less than forthcoming about the Epstein relationship, Black announced he would step back from the company effective April 2021. But in March, he abruptly resigned a month early, with little explanation. This writer can now reveal that his resignation came on the heels of a second subpoena issued in January 2021, requesting all photos, videos, and records of his visits to Little St. James—Epstein’s private island in the U.S. Virgin Islands—as well as any records of Black’s communications with Epstein regarding investments in Apollo, and evidence relating to any loan agreements between the two men. This January subpoena is the first mention of possible ties between Epstein’s financial operations and the workings of Apollo Management itself, one of the largest investment banks in the world, with assets over $400 billion.

Investigators have also recently subpoenaed Jean Luc Brunel, a widely-known French modeling scout who was arrested on charges of rape late last year. U.S.V.I. officials sent subpoenas to several modeling companies, MC2 Model and Talent Miami LLC, The Source Models LLC, and Identity Model LLC. The investigators want information relating to any models procured to Epstein for work, or transported to Little St. James for other illicit purposes. Investigators claim Epstein, in addition to abusing a number of girls and women himself, procured them for and pressured them to have unlawful sex with business partners and politicians.

While Epstein’s alleged accomplice, Ghislaine Maxwell, is now under indictment in New York for human trafficking charges similar to the ones Epstein faced shortly before his demise, the criminal case against her is limited in scope and does not yet appear to involve the pursuit of a financial probe. Investigators in the U.S. Virgin Islands, who are local in nature and are not a wing of the U.S. Department of Justice, have become the first United States law enforcement agency to formally claim Epstein, a convicted pedophile, ran a massive human trafficking ring between 1998 and 2019 and used a web of companies that inexplicably received hundreds of millions in compensation to operate a criminal enterprise that reached around the world.

Two years ago this August, the American public will mark the second anniversary of the sudden, violent death of Epstein in a New York prison cell, an event that promises to serve as conspiracy theory fodder for decades to come. Epstein’s demise, which occurred shortly after his federal indictment on sex trafficking charges and a judge’s denial of his request to be released on bail, deprived the many victims of his extensive sexual abuse and human trafficking operation from a sense of justice or accountability.

Many Americans were quick to speculate Epstein was probably murdered, despite repeated insistence from New York and federal officials that his death was a suicide. That speculation is unlikely to abate anytime soon. A number of media outlets predicted Epstein’s many secrets about other sexual predators and compromised power-brokers would likely die with him. Stories about Epstein’s connections to Donald Trump, Bill Clinton, Prince Andrew, Bill Gates, Alan Dershowitz, Les Wexner, and dozens of other powerful men (and women) have emerged in the months since his demise. But the coverage has amounted to little more than a tabloid reckoning for each new person tied to Epstein, most barely lasting longer than a single news cycle. An official accounting of Epstein’s operation, and his ties to American, British, Saudi, Israeli, and Russian government figures, has been lacking.

Yet both Epstein’s victims and the American public might be closer to truth and some measure of justice in the Epstein case than they think, in part thanks to the U.S.V.I. investigation.

Even as many Americans espoused a sense of hopelessness about the prospect of a public exposure of the mysteries surrounding Epstein’s misconduct, this investigation has been quietly underway in a tropical paradise. Judging by the subpoenas issued as recently as June, it has now evolved into a sprawling investigation of Epstein’s financial network and entire human trafficking operation. For all the reporting on Epstein’s ties to foreign governments, his unexplained fortune, his incomparable political connections to presidents and princes, no public record has been compiled and published by any government entity or investigative body about his operation.

After twelve months of subpoenas to a variety of entities, the Epstein Estate’s lawyers Indyke and Kahn moved the court overseeing the case to move the lawsuit to the Complex Litigation Division. They argued that a Virgin Islands Rule requires such a transfer when cases demand “exceptional judicial management to avoid placing unnecessary burdens on the court or the litigants and to expedite the case.” Their arguments revealed how expansive the case had become:

there are twenty-three claims under the Criminally Influenced and Corrupt Organizations Act, U.S.V.I.’s civil RICO law;
there are ten unnamed defendants, mostly Epstein’s agents and his corporations
the Government claims Epstein’s latest company fraudulently obtained more than $70 million in tax benefits
the allegations span two decades, and subpoenas seek information from parties dating as far back as at least 1998
the Attorney General “to date . . . has issued subpoenas to sixty-five (65) non-parties” including individuals, corporations, and financial institutions

U.S.V.I. investigators did not disagree. They consented to the determination that the case was complex, meaning it is likely it will be moved to the alternative Complex Litigation division. The subpoenas demonstrate that investigators believe they must unravel Epstein’s financial empire, which spans dozens of companies and was reportedly worth more than $500 million at various points, to obtain an adequate understanding of the civil scheme they are accusing the “Epstein Enterprise” of undertaking. In addition to demands for information from Apollo, Wells Fargo, Barclays, and other financial businesses, investigators have sent subpoenas to auction houses Christie’s and Sotheby’s seeking documents related to Epstein’s transactions related to the purchase or sale of fine art, a practice sometimes associated with international money laundering.

Earlier subpoenas directed to Leon Black were accompanied by other subpoenas to several art holding companies called Narrows Holdings and Narrows Holdings II, which Black appears to have used to acquire art. Black is the owner of a $1 billion collection of fine art, most of which is currently on display at the Museum of Modern Art (MoMA) in New York City. But the second set of subpoenas suggests law enforcement officials may think Epstein transacted fine art to Black in exchange for monetary loans.

One subpoena to the Chicago Deferred Exchange Company asked for all documents related to transactions with Epstein, as well as information about Epstein and several other individuals whose names are redacted. But a nugget hidden in the bottom of the subpoena suggests the request is related to Black and fine art: the subpoena demands all documents related to “In the Matter of the Petition of CDECRE Artwork Eat LLC.” The case was a New York tax dispute between CDECRE Artwork Eat LLC and the state of New York over fine art purchased for $139 million from Black’s company, Narrows Holdings.

The second subpoena issued to Black in January 2021 mentions the company he uses to manage his family trust, Elysium Management. Investigators indicate in the subpoena that they seek information about loans, art transactions, and the general operation of Elysium Management with respect to Epstein.

Whether criminal prosecutors are examining whether Black helped Epstein launder fine art in exchange for U.S. money remains unclear.

The other allegations in the wide-ranging investigation go to whether Epstein forced young girls and women into marriages (35 redacted names in total) in order to evade immigration laws; whether Epstein and his lawyers, Indyke and Kahn, used several Florida-based charity companies to funnel money from U.S.V.I. to others in the United States; records related to private investigators Epstein employed for the purposes of surveilling his victims who were pursuing civil or criminal cases against him. A number of the subpoenas include a redacted group of five or six individuals whom it appears investigators consider Epstein’s inner circle and part of his massive operation.

U.S.V.I. investigators amended the initial complaint for the second time in February 2021, adding new details about a 20-year old woman whom they say was flown by Epstein and his associates to Little St. James, abused by Epstein, and then pressured to have sex with Epstein’s business associates. According to law enforcement, Epstein and his associates forced the woman into marriage in order to prevent another victim from being deported. So far, investigators have claimed Epstein and others forced three marriages between female victims and foreign victims to make it easier to transport them.

The judge recently set a briefing schedule for the issue of whether the reassign the case to the Complex Litigation Division, an outcome which seems likely based on the arguments from both sides. However, the re-designation is unlikely to deter investigators from continuing their aggressive approach and sharing evidence with appropriate authorities in New York, Florida and elsewhere, who could pursue further criminal charges against individuals involved in the Epstein Enterprise. Local and federal prosecutors across the United States—from New Mexico to New York to Florida—may have reason to pay attention to the U.S.V.I. investigation. While New York prosecutors are going after Maxwell, it appears dozens of other individuals have not yet been charged or even scrutinized for their involvement with Epstein.

For example, Epstein’s relationship with former president Donald Trump appears to have received remarkably sparse scrutiny from law enforcement. Vanity Fair reported that in 2004, Epstein reportedly told Trump about financial plans to buy an estate near Mar-a-Lago in Palm Beach. The property had previously been owned by Les Wexner, the Victoria’s Secret mogul who is responsible for a large part of Epstein’s financial success in the 1990’s and 2000’s. Wexner had sold the house to a Massachusetts nursing home magnate named Abe Gosman, who later transferred it to his wife, Linda, in an effort to avoid bankruptcy creditors in 1999. After the Gosmans ultimately lost their fortune, the property went to bankruptcy auction in 2004.

According to Vanity Fair, after Epstein told Trump of his plans to make a bid on the property, Trump scooped Epstein on the purchase, offering $1 million above what Epstein offered. The purchase was financed by Deutsche Bank. Trump then sold it to a wealthy Russian named Dmitry Rybolovlev—another fine art connoisseur in the vein of Leon Black. What’s worse, Trump sold the property for an inexplicable $50 million markup without making any substantive improvements to the property, an indicator that the transaction might have been an effort to launder Rybolovlev’s money into a legitimate investment. Trump’s move reportedly led to a falling out between he and Epstein, which caused Epstein to tell several friends that he had compromising photos of Trump with topless underage girls. The Vanity Fair account alone is rife with information for investigators to pursue. U.S. law enforcement agencies would do well to stay tuned to the U.S.V.I. probe.

*Interesting aside: after their departure from the Palm Beach mansion, Abe and Linda Gosman moved into a condo at Trump Tower West Palm Beach using a $1.14 million mortgage secured by—you guessed it—Deutsche Bank, which at the time was just beginning its lengthy suspect relationship with Trump. Linda was later prosecuted for tax and mortgage fraud. She was ultimately convicted and sentenced to two years house arrest. Deutsche Bank foreclosed on their condo property in 2009, one year after Trump sold the Palm Beach property to Rybolovlev for a $50 million profit.

Creatures of the Swamp

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