TLDR
Epstein's financial flows traversed five U.S. jurisdictions — New York, Delaware, Florida, the U.S. Virgin Islands, and Puerto Rico — plus Liechtenstein, passing through Deutsche Bank, TD Bank, Charles Schwab, FirstBank Puerto Rico, and Morgan Stanley. This multi-jurisdictional, multi-institutional structure matches the anti-money laundering pattern known as jurisdictional arbitrage: each border crossing adds a layer of regulatory separation that no single examiner can see through (TD Bank, 2019; NYDFS, 2020; PAPER TRAIL Project, 2026).
The Architecture of Complexity
When anti-money laundering analysts describe "jurisdictional layering," they mean something specific: routing funds through multiple legal jurisdictions so that no single regulator has visibility into the complete transaction chain. Each jurisdiction has its own banking regulators, its own reporting requirements, and its own enforcement priorities. A wire transfer that crosses three jurisdictions effectively requires three separate investigations to trace end to end. The Epstein financial network was built to exploit this fragmentation.
Five Jurisdictions, Five Banks
The TD Bank Suspicious Activity Report (SAR — a report banks must file when they detect potential financial crime) and the NYDFS consent order, taken together, document wire transfers flowing through five financial institutions: Deutsche Bank (New York), TD Bank (multiple branches), Charles Schwab, FirstBank Puerto Rico, and Morgan Stanley (TD Bank, 2019; NYDFS, 2020). The corporate entities that held these accounts were registered across five U.S. jurisdictions.
New York hosted the operational core: NYSG LLC, NES LLC, and HBRK Associates all maintained addresses at 575 Lexington Avenue or 9 East 71st Street. Delaware provided the corporate formation haven: JEGE Inc. and Hyperion Air Inc. were both Delaware corporations, using Corporation Trust Company at 1209 N. Orange Street, Wilmington — the same registered agent address shared by over 300,000 other entities. Florida contributed short-lived intermediaries like Harlequin Dane LLC and Birch Tree Br LLC. The U.S. Virgin Islands served as the destination for the corporate migration: Southern Trust, Southern Financial, Financial Trust Company, JEGE LLC, F T Real Estate, and NES LLC (post-2013) all clustered at 6100 Red Hook Quarter B3, St. Thomas (PAPER TRAIL Project, 2026).
Then there was Liechtenstein. HBRK Associates wired $20,000 to Walch Schurti attorneys for "retainer purchase of shares Anstalt," the standard formation structure for a Liechtenstein Anstalt — an asset protection vehicle (a type of corporate entity designed to shield assets from creditors and legal claims) with no requirement to disclose beneficial owners publicly (TD Bank, 2019).
The Migration Pattern
The jurisdictional structure was not static. It migrated. JEGE Inc. was incorporated in Delaware in 2000. By 2012, JEGE LLC had been filed in the USVI — not replacing the Delaware entity, but paralleling it. NES LLC changed its address from 9 East 71st Street (New York) to 6100 Red Hook Quarter (USVI) on October 16, 2013. Southern Trust Company obtained a 90% income tax exemption from the USVI Economic Development Commission for "DNA database consulting" — a business the USVI Attorney General later found had no evidence of legitimate scientific activity (PAPER TRAIL Project, 2026).
This migration from New York and Delaware to the U.S. Virgin Islands was not about operational convenience. It was about regulatory arbitrage — exploiting the differences between jurisdictions' rules to gain an advantage. The USVI offered territorial tax benefits unavailable on the mainland, while still providing access to U.S. banking infrastructure. The result was a structure where funds could move between a New York bank account and a USVI entity without crossing an international border — but with the regulatory fragmentation of an offshore jurisdiction.
Three Jurisdictions in One Wire
The most concentrated example of jurisdictional layering in the corpus is a single wire transfer. F T Real Estate Inc. (a USVI entity) held a FirstBank Puerto Rico account (7171030966). From that account, $3 million was wired to Darren Indyke's personal TD Bank checking account for the purchase of 6030 Le Lac Road in West Palm Beach, Florida. One wire crossed three jurisdictions: USVI entity, Puerto Rico bank, Florida real estate (TD Bank, 2019).
Another example: Southern Country International (USVI) held a Charles Schwab account (14332170) that wired $1.66 million to HBRK Associates at TD Bank in New York. The entity is USVI-registered. The brokerage account is at a national firm. The destination is a New York bank. Each institutional and jurisdictional boundary represents a point where regulatory visibility drops (TD Bank, 2019).
Why It Works
Jurisdictional layering works because financial regulation is organized by geography. A New York banking examiner reviewing TD Bank transactions sees incoming wires from Charles Schwab — a regulated U.S. brokerage. The examiner does not automatically see that the Charles Schwab account belongs to a USVI entity whose sole officer is also the sole officer of the entity that sent the original funds from Deutsche Bank two hops earlier. To reconstruct that chain, the examiner would need to coordinate across the New York Department of Financial Services, the SEC (Schwab's regulator), and the USVI Inspector General's office. In practice, that coordination rarely happens without a specific criminal referral.
The five-jurisdiction structure did not need to defeat sophisticated investigation. It needed to defeat routine monitoring — the automated transaction screening and compliance reviews that banks perform on thousands of accounts daily. Each jurisdictional crossing made the automated pattern less obvious. By the time the TD Bank SAR was filed in October 2019, the money had been moving through these channels for years (TD Bank, 2019).
The $20,000 to Liechtenstein adds one more dimension. Any investigation following the money from Southern Financial through HBRK to Walch Schurti encounters a sovereign jurisdiction with banking secrecy protections that no U.S. subpoena can penetrate without a mutual legal assistance treaty request (a formal process for one country to seek legal evidence from another). That wire was the smallest in the corpus. It may also be the one designed to be the hardest to follow.
References
NYDFS. (2020). Consent order: In the matter of Deutsche Bank AG. New York Department of Financial Services. https://www.dfs.ny.gov
PAPER TRAIL Project. (2026). Corroboration report [Data set].
PAPER TRAIL Project. (2026). Entity ownership research [Data set].
TD Bank. (2019). Suspicious Activity Report (BSA-31000155070501). Filed October 1, 2019.