UT (Tax & Chancery) UT-2023-000064 - [2025] UKUT 00203 (TCC)

The full text of the final version read as follows:

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Thank you for this opportunity to speak to the Committee. I wanted to be here in person because I value so highly my association with Bowdoin, which spans forty-four years of my life, and my reputation, which I strongly believe should not be sullied by my association with JE.

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Given my long relationship with JE, and particularly in light of the recent understanding of the enormity of his evil, I understand the questions you may have regarding that relationship, and am here to answer those questions.

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Let me be clear from the outset: At no time was I aware of JE’s inappropriate relationship with underage girls prior to the original charge in 2006 and I have never witnessed at any time the allegations made against him.

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At no time was I interviewed or subpoenaed to testify as a witness in these investigations. At no time after his conviction in 2008 did I allow JE any connection with any aspect of my professional life. Indeed, I have never had any professional relationship with JE except for his relationship with JP Morgan’s private bank, which began long before I ever met him. That said, I had limited contact with him post his conviction, which I will describe shortly.

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At no time in our professional relationship did I arrange to compensate JE for professional introductions he made or for investment advice or for any other form of advice he may have rendered to JP Morgan; nor, to my knowledge, did JP Morgan ever compensate JE.

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At no time during my tenure at Blue Mountain capital did I conduct any business with JE.

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At no time during my tenure at Barclays have I or the bank conducted any business with JE.

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At no time have I involved JE in any aspect of my support for and dedication to Bowdoin College.

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Let me take you through the history of my connection to Jeffrey Epstein

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I first met him in late 1999 or early 2000 when I took over the Private Bank at JP Morgan

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I was introduced to him by the then CEO of JP Morgan because Epstein was at the time a client of the Private Bank, and the CEO felt he was someone I should know and steward as a client.

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Epstein proved to be extremely well networked – which tallies with the picture of him in the media – and he began to introduce and recommend clients to me, and in turn to JP Morgan.

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Over the next 7 to 8 years he and I became professionally fairly close – predicated on this propensity to introduce business to JP Morgan

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As I have mentioned, as far as I know, JE was not paid any fees by JP Morgan for any service ever – including for those introductions that he made.

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I never paid Jeffrey Epstein any fees for any service ever, either personally or professionally Subsequent to his conviction and incarceration, I did not personally, or professionally, transact any business with him at all. The business I was then running at JP Morgan – the Investment Bank – did not have Epstein as a client, and nor did he introduce business to the IB during my tenure. Also, I never conducted business with JE while at Blue Mountain Capital or at Barclays

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Over the years, I have had meetings with JE that varied in frequency. Pre his 2008 conviction, most of these meetings took place in his office in midtown Manhattan, which he maintained prior to his incarceration. Post his conviction, the meetings took place at the office which he maintained in his home in Manhattan. At no time during these meetings did he reveal or discuss any aspect of the conduct that was the subject of his recent indictment.

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After his conviction, I attended roughly 1 dinner per year hosted by Jeffrey – most often with multiple guests. And I have only ever been at a social gathering with him once.

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He has never visited my home as a guest.

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I have visited his island twice. Once I was with my wife and daughters in transit to a boat. The second time, I stopped off at his island with my wife for a couple of hours in April of 2015 when we were vacationing in the Caribbean and were passing his home. At no time during either visit did I or my family witness any of the conduct for which he was convicted in 2008 or indicted earlier this year.

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As has been reported, I visited Epstein during his incarceration on one occasion in 2008/09. That visit took place for under an hour in the office he was using for work release while serving his sentence. Our conversation centred on his experience in jail.

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My view at the time was that he had pleaded guilty to a crime and was rightly punished.

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He was someone I had known well and I felt it was right to offer him support.

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At that time, I had no way of knowing that his conviction in 2008 was not sufficient to encompass the extent of his crimes. To my knowledge, he had been investigated thoroughly, tried and convicted.

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In Dec 2015, I assumed my position at Barclays and moved to London. I have not had any contact with him since then.

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Of course, with the benefit of hindsight, I wish that I had never had a relationship with Jeffrey, let alone severed it earlier.

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In sum, I have thought long and hard about my relationship with JE. I abhor his conduct. I regret that I was unaware of it. But I have not behaved in any way which could be regarded as untoward or improper.

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Given the public attention surrounding the JE case, I understand why the Committee felt compelled to hear from me on this matter. I wanted you to hear the truth from me, in person, because I so value my association with this college and the reputation I have built here and during my career for integrity.

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I arrived in Brunswick in 1975 and in many ways I have never left. I have contributed countless hours to the college’s welfare. I sent one of my daughters here, and have enthusiastically recommended Bowdoin to numerous friends through the years.

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I have served for 12 years now on its Board of Trustees. It has been my pleasure and privilege to do so.

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I understand what is at stake here, and let me be clear: To judge my merits to be a Bowdoin trustee based on a limited relationship with an individual completely removed from the college and completely removed from the person I believe myself to be, would be to take guilt by association to a frightening and unwarranted extreme.

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The college should judge those who make up its community based on who they are and the values they uphold. The Bowdoin community has known me for forty-four years; the values I have upheld have been the values inculcated in me by my family, my friends, and in no small measure, by my experiences here.

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Accordingly, I am gratified that since the articles have been published on my visits to JE, there have been virtually no calls, that I am aware of, for my separation from Bowdoin. There have been, instead, only understandable calls, from some, for me to explain the relationship I had with JE. Now that I have done that, I will take your questions and await your guidance. Thank you.”

In our view, the document gave the same impression to the Bowdoin College Trustees as had been given to journalists in July and August 2019, namely that any close professional relationship Mr Staley had had with Mr Epstein was during the time that Mr Staley headed JPM’s private bank, and particularly during the period 2000-2008. The fifth bullet point in the document, as set out above, read:

“At no time after his conviction in 2008 did I allow JE any connection with any aspect of my professional life. Indeed, I have never had any professional relationship with JE except for his relationship with JP Morgan’s private bank, which began long before I ever met him. That said, I had limited contact with him post his conviction, which I will describe shortly.”

As stated in the fourteenth bullet point in the document, it was stated that over the 7 or 8 years since the relationship commenced “he and I became professionally fairly close – predicated on this propensity to introduce business to JP Morgan.”

The document did refer to specific points of contact with Mr Epstein after 2008, such as twice visiting his island or visiting him whilst on work release, but we agree with the Authority that the overall impression was still not a full picture, and did not rectify the wrong impression that any “close professional relationship” had pre-dated 2008. The disclosure of the April 2015 island visit was incomplete, as it failed to make clear that Mr Staley had travelled on Mr Epstein’s plane in order to reach the Caribbean: instead, the impression given was that Mr Staley had happened to be in the area and decided to stop by the island.

Although it was said that Mr Staley “had meetings with JE that varied in frequency” after 2008, the only detail given was that Mr Staley “attended roughly 1 dinner per year hosted by Jeffrey – most often with multiple guests.”

The document also stated that Mr Staley had “only ever been at a social gathering with him once” and that Mr Epstein had never visited his home as a guest.

Neither Mr Hoyt nor Mr Higgins in their evidence could point to much by way of significant information about the relationship between Mr Epstein and Mr Staley which was not reflected in the Bowdoin College Talking Points.