Illegal Activity
concerning
Blackmail
none
Date
2013-08-26
Document Type
other
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:41
Summary
This document outlines the due diligence performed for opening a checking account for Zorro Management LLC, owned by Jeffrey Epstein. The relationship is classified as high-risk due to Epstein's past legal issues, but AML Compliance has approved continuing the relationship.
Metadata
- Subject
- Zorro Management, LLC - High Risk Relationship
- Sender
- Stewart Oldfield
- Recipients
- —
- Document ID
- 83290/ 01651789
- Date
- 2013-08-26
Illegal Activity
- Severity
- concerning
- Description
- The document describes past illegal activities committed by Jeffrey Epstein, including fraud, sexual assault, and insider trading. While these are past events, the fact that they are being used to classify the relationship as high-risk is concerning.
- Categories
- FraudSexual misconductInsider trading
- Content Type
- first_hand
Evidence:
- SEC filed a settled civil fraud action for illegal insider trading.
- Epstein was sentenced to 21 months in federal prison for three counts of fraud, sexually assaulting a girl and solicitation of prostitution.
Relationships 2
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Stewart Oldfield | Business | Zorro Management, LLC | Stewart Oldfield is the RM (Relationship Manager) for Zorro Management, LLC. |
| Zorro Management, LLC | Ownership | Jeffrey Epstein | Jeffrey Epstein is the UBO (Ultimate Beneficial Owner) of Zorro Management, LLC. |
Notable Quotes 2
This relationship is deemed high risk due to multiple court cases on Jeffrey Epstein, involving 22 April 2004 SEC filed a settled civil fraud action for illegal insider trading in three publicly traded Massachusetts banks.
All negative media and alerts have been reviewed by AML Compliance and they do not see a reason to discontinue the existing relationship with Jeffrey Epstein.
Red Flags 2
- The client, Jeffrey Epstein, has a history of legal issues, including a settled civil fraud action with the SEC and a prison sentence for fraud and sexual assault.
- The relationship is deemed high risk, but AML Compliance does not see a reason to discontinue it.
Financial Information
Amounts:$224mn$72532.06
Assets:
- 21 deposit accounts
- 3 money market accounts
- 5 brokerage accounts
- 1 custody account
Transactions:
- Disgorgement of trading profits
- Prejudgment interest
- Civil penalties
Media & Journalist References
- Mentions of negative media related to Jeffrey Epstein.
Public Knowledge
- Context
- Jeffrey Epstein's legal issues and associations have been widely reported in the media.
- Media Worthy
- Yes
- Likely Public
- True
Legal Compliance
- Jeffrey Epstein's past legal issues, including a settled civil fraud action with the SEC and a prison sentence for fraud and sexual assault.
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowLegal matters/litigationBusiness dealingsAllegations/complaintsIllegal activities
People 2
Organizations 5
Zorro Management, LLCUS OnshoreSECAML ComplianceMassachusetts banks
Text Analysis
- Tone
- Informative
- Purpose
- To document the opening of a checking account for Zorro Management LLC, a high-risk client due to Jeffrey Epstein's past legal issues, and to justify the business relationship despite the high risk factors.
- Significance
- This document highlights the due diligence process undertaken when dealing with a high-risk client like Jeffrey Epstein, including the review of past legal issues and negative media.
File Info
- File Name
- EFTA01356815.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:41:03.368065
- DOJ Source
- View on DOJ