TLDR
HBRK Associates wired $20,000 to Walch Schurti, a Liechtenstein law firm, with the memo "retainer purchase of shares Anstalt." An Anstalt is a Liechtenstein legal structure similar to a foundation, used to hold assets privately — with no requirement to disclose who ultimately benefits from it. This wire adds a sixth jurisdiction to the documented Epstein financial network and the only one outside U.S. territory.
The Wire
The evidence is a single wire transfer. HBRK Associates, operating from TD Bank account 4332216963 under Richard Kahn's sole authorization, sent $20,000 to Walch Schurti attorneys in Liechtenstein (PAPER TRAIL Project, 2026a). The wire memo reads: "retainer purchase of shares Anstalt."
This is not a large wire by the standards of the Epstein financial network, where individual transfers reached $8 million. But its significance lies not in the amount but in what it reveals about the geographic reach of the financial architecture.
What an Anstalt Is
An Anstalt (German for "establishment" or "institution") is a legal structure unique to Liechtenstein and a small number of other civil law jurisdictions. Unlike a corporation or LLC, an Anstalt has no shareholders in the traditional sense. It can hold assets, conduct business, and make distributions — but it has no requirement to publicly disclose who ultimately benefits from its assets (the "beneficial owner").
This opacity is the Anstalt's defining feature. In most jurisdictions, corporate registries require disclosure of directors, officers, or beneficial owners. An Anstalt can be structured so that the identity of the person who benefits from its assets is not recorded in any public registry. The only people who know who controls the Anstalt are the Anstalt itself and its attorneys.
Liechtenstein has historically been one of the most secretive financial jurisdictions in the world. While the country has made reforms under international pressure (including signing tax information exchange agreements), the Anstalt structure remains available for those seeking asset protection with minimal disclosure.
"Purchase of Shares"
The wire memo specifies "purchase of shares Anstalt" — not creation or establishment of an Anstalt (PAPER TRAIL Project, 2026a). This phrasing indicates that an Anstalt already existed and that HBRK Associates was acquiring an interest in it. The Anstalt was not being set up fresh; it was an established structure into which the Epstein network was buying.
The "retainer" component suggests that the $20,000 also included ongoing legal representation fees. Walch Schurti is a Liechtenstein law firm specializing in trust and foundation structures, corporate law, and asset protection (PAPER TRAIL Project, 2026a). Their involvement indicates professional-grade structuring, not a casual transaction.
The Sixth Jurisdiction
Prior to this wire, the documented Epstein financial network spanned five jurisdictions (PAPER TRAIL Project, 2026b):
- New York — Corporate registrations (NES LLC, HBRK, DKI PLLC), Deutsche Bank accounts, 575 Lexington operations
- Delaware — JEGE Inc., standard shell company incorporations
- Florida — Harlequin Dane LLC, Palm Beach residence, state prosecution
- U.S. Virgin Islands — Southern Trust, Southern Financial, JEGE LLC, Financial Trust Company, EDC tax exemption (a special tax break from the USVI government)
- Puerto Rico — FirstBank PR accounts (F T Real Estate, Southern Trust)
The Walch Schurti wire adds Liechtenstein as the sixth documented jurisdiction and the first outside U.S. sovereign territory. While the USVI offers favorable tax treatment and some jurisdictional advantages, it remains subject to U.S. federal law, U.S. banking regulations, and U.S. court jurisdiction. Liechtenstein is a foreign sovereign state with its own legal system, its own banking secrecy traditions, and its own resistance to international legal cooperation.
What We Do Not Know
The corpus contains no further information about the Anstalt. Its name is not recorded. Its purpose is not described. Its asset holdings are unknown. The wire transfer is the beginning and end of the evidentiary chain (PAPER TRAIL Project, 2026a).
We do not know whether the Anstalt was established specifically for the Epstein network or whether it predated the relationship. We do not know what assets it held, whether it made distributions, or whether it still exists. The $20,000 wire is a single thread leading into Liechtenstein's legal system, where the trail goes dark.
This is what makes the finding significant and frustrating in equal measure. The wire proves that the Epstein network maintained relationships with Liechtenstein asset protection structures. It proves that Kahn, through HBRK, authorized the payment. It proves that a law firm specializing in opaque foundation structures was retained. But it does not prove what was in the Anstalt, what it was used for, or how much money it held.
The Broader Context
The Liechtenstein wire sits within a larger pattern of international financial activity. French entities received $1.575 million in wire transfers. Lithuanian entities received approximately $103,000 (PAPER TRAIL Project, 2026b). The Butterfly Trust made disbursements to beneficiaries across multiple countries. The Anstalt wire adds another data point to the international footprint — but unlike the French or Lithuanian connections, the Liechtenstein thread leads to a jurisdiction specifically designed to prevent further investigation.
For investigators with subpoena power — particularly the four countries that have opened formal criminal investigations — the Walch Schurti wire provides a starting point for mutual legal assistance requests. For a public corpus analysis, it is a wall.
References
PAPER TRAIL Project. (2026a). TD Bank SAR extraction: HBRK wire to Walch Schurti ($20K, "retainer purchase of shares Anstalt"), HBRK account details, and Walch Schurti specialization [Research file]. td_bank_sar_extraction.md. Key Intelligence Finding #4.
PAPER TRAIL Project. (2026b). Five-jurisdiction financial network and entity ownership [Research file]. ENTITY_OWNERSHIP.md; td_bank_sar_extraction.md.
TD Bank. (2019, October 1). Suspicious Activity Report (BSA-31000155070501). Filed with Financial Crimes Enforcement Network. Document EFTA01656524.pdf.