US Virgin Islands Department of Justice reaches $75 million victim-supporting settlement with JPMorgan

United States Virgin Islands Attorney General Ariel M. Smith recently announced that the USVI Department of Justice had reached a historic victim-supporting settlement with JPMorgan Chase. The settlement includes significant commitments by JPMorgan Chase to curtail human trafficking and payments by JPMorgan Chase to the USVI DOJ totaling $75 million. The agreement resolves the enforcement action filed by the USVI DOJ, which marked the first time a state attorney general has used the authority provided by the Trafficking Victims Protection Act. This is also the first enforcement action filed against a bank for facilitating and profiting from human trafficking.

“As part of the settlement, JPMorgan has agreed to implement and maintain meaningful anti-trafficking measures, which will help prevent human trafficking in the future. This settlement is a historic victory for survivors and for state enforcement, and it should sound the alarm on Wall Street about banks’ responsibilities under the law to detect and prevent human trafficking,” said Attorney General Smith. “Our Department of Justice tirelessly pursued this enforcement action to make it substantially harder for traffickers to finance their crimes in the future, and we are confident this settlement will help achieve that goal. We are proud to have stood alongside the survivors throughout this litigation, and this settlement reflects our continued commitment to them. With this constructive resolution of this groundbreaking litigation, we look forward to helping our community move forward and to building a new relationship with JPMorgan.”

As the USVI DOJ designated, a large portion of resources from the settlement agreement will be given to local charities to support those in vulnerable communities who are victims of crimes, including human trafficking and domestic violence; strengthen USVI Department of Justice initiatives to enhance public safety and combat crime; and create a $10 million fund to provide mental health services for Jeffrey Epstein’s survivors.

The settlement agreement includes several substantial commitments by JPMorgan Chase to identify, report, and cut off support for potential human trafficking, including establishing and implementing comprehensive policies and procedures to:

• Inform law enforcement when customers are identified as involved in human trafficking;
• Terminate customers’ accounts if JPMC has credible information that the account is engaged in or facilitating human trafficking;
• Ensure accounts are not opened in the private bank without satisfactory due diligence;
• Identify and escalate clients associated with forced or child labor, human trafficking, or slavery and not provide banking, lending, or other services to clients where there is credible information of forced or child labor, human trafficking or slavery;
• Facilitate appropriate escalation and remediation of issues in the event JPMC identifies any violation of human trafficking laws by a JPMC supplier through firm-wide operational risk practices; and
• Conduct annual employee training on policies and procedures to identify, report, and address evidence of human trafficking by JPMC customers.

Additionally, as part of the settlement agreement, JPMorgan Chase has committed to learning from the perspectives of experts and survivors of sex trafficking, supporting a robust transaction monitoring program to detect potential crimes, and conducting annual reviews of its anti-money laundering program.