UT (Tax & Chancery) UT-2023-000064 - [2025] UKUT 00203 (TCC)
Fecha: 03-Abr-2025
The accuracy of the Statements in the Letter
The accuracy of the Statements in the Letter
The nature and extent of the relationship between Mr Staley and Mr Epstein
The period before Mr Epstein’s conviction in 2008
From 1999 until 2001 Mr Staley was head of JPM’s Private Bank. During this time, Jeffrey Epstein was a client of the Private Bank and was introduced to Mr Staley. In 2001 Mr Staley became CEO of JP Morgan Asset and Wealth Management which he ran until 2009. He reported to Mr Jamie Dimon, the CEO of JPM. Ms Mary Erdoes, who then ran the Private Bank, reported to Mr Staley.
Although Mr Staley, in common with many other influential and respected individuals who came to be associated with Mr Epstein, now regrets that he was associated with Mr Epstein because of the clear evidence that he was a serial sex offender, the association began because Mr Staley regarded Mr Epstein as a highly successful and skilful financier with unique insights into world and United States economics. Mr Staley liked Mr Epstein and respected his views on a wide range of subjects. Mr Staley regarded Mr Epstein as an individual with remarkable connections and a willingness to assist with networking and introductions. He capitalised upon the access he was able to gain to many prominent and influential individuals which led to his cultivation of a substantial network of people in politics, economics, philanthropy, popular culture and science.
The Chief Executive at JPM recommended that Mr Staley should become acquainted with Mr Epstein because he was an exceptionally well-connected man who could help Mr Staley, in his capacity as a senior executive at JPM, to form business relationships with influential and other well-connected individuals with whom he might not otherwise have met or with whom it would have taken much longer to establish a relationship.
Mr Staley explained why he developed and maintained a professional relationship with Jeffrey Epstein as follows:
He considered that Mr Epstein was an important client to JPM and particularly the private bank.
Given his connections, he also had access to a good deal of valuable information. He could facilitate access to potential clients, world leaders and people of influence in politics and economics.
Mr Staley turned to Mr Epstein for advice relating to business and to his own career. Mr Epstein provided such advice because he sought to assist, build and enhance his network of which Mr Staley was a part, which in turn enhanced him.
Mr Staley confirmed that Mr Epstein continued to be part of his network when he left JPM’s Private Bank to run JPM’s Investment Bank.
- Heading
- INTRODUCTION
- BACKGROUND TO THE REFERENCE
- THE AUTHORITY’S CASE AND MR STALEY’S POSITION
- APPLICABLE LAW AND REGULATORY PROVISIONS
- Rules of conduct
- Prohibition
- Fitness and propriety
- Law relating to integrity
- Financial Penalty
- Step 1: Disgorgement
- ISSUES TO BE DETERMINED AND THE ROLE OF THE TRIBUNAL
- Issues to be determined
- Context
- What is not in issue in this reference
- Standard and burden of proof
- EVIDENCE
- Mr Staley’s evidence
- Documentary evidence
- FINDINGS OF FACT
- The accuracy of the Statements in the Letter
- The period after Mr Epstein’s conviction until Mr Staley left JPM at the end of 2012
- Mr Epstein simply responded “family”
- The period after Mr Staley left JPM at the end of 2012 until he joined Barclays in 2015
- Evaluation of the relationship
- The recency of the last contact between Mr Staley and Mr Epstein at the time the Letter was written
- What Mr Staley told Barclays about his relationship with Mr Epstein
- Period prior to Mr Epstein’s arrest in July 2019
- Period following Mr Epstein’s arrest on 6 July 2019
- Bowdoin College Talking Points
- The process of drafting of the Bowdoin College Talking Points
- Final version of the Bowdoin College Talking Points
- Content of the final version of the Bowdoin College Talking Points
- Presentation to Bowdoin College
- Conclusion on Barclays’ knowledge of the relationship
- The scope of the Authority’s enquiry in August 2019
- The origin of the Authority’s enquiry
- What was said on the call of 15 August 2019
- Conclusion on the scope of the Authority’s enquiry
- The preparation of the Letter and Mr Staley’s approval of it
- October 2019: Drafting of the Letter
- Second draft
- Telephone calls with Mr Gillies: 2 and 4 October
- The call between Mr Higgins and Mr Davidson on 4 October
- Further drafts: 5 and 6 October
- The call of 7 October between Mr Hoyt and Mr Staley
- Finalisation of the Letter
- THE AUTHORITY’S INVESTIGATION
- The Scope of the Authority’s Initial Enquiry in 2019
- Materiality of the Statements
- Accuracy of the Statements
- Recklessness of approving the Statements
- Whether Mr Staley knew that the Statements were inaccurate
- Whether Mr Staley was aware that there was a risk that the Statements would mislead the Authority
- Conclusions