Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 122-cv-10904 (S.D.N.Y. 2022)/263-04.pdf

EXHIBIT 57 Case 1:22-cv-10904-JSR Document 263-4 Filed 08/07/23 Page 1 of 3 Confidential - Francis Pearn Golkow Litigation ServicesPage 1 00001 2 UNITED STATES DISTRICT COURT FOR THE 3 SOUTHERN DISTRICT OF NEW YORK 4 5 Case No. 1:22-cv-10019 (JSR) - - - - - - - - - - - - - - - - - -X 6 JANE DOE 1, Individually : and on behalf of all others : 7 similarly situated, : Plaintiffs : 8 : VS : 9 : JPMORGAN CHASE BANK, N.A., : 10 Defendant : - - - - - - - - - - - - - - - - - -X 11 Case No. 1:22-cv-10904 (JSR) - - - - - - - - - - - - - - - - - -X 12 GOVERNMENT OF THE UNITED STATES : VIRGIN ISLANDS : 13 Plaintiffs : : 14 VS : : 15 JPMORGAN CHASE BANK, N.A., : Defendant : 16 - - - - - - - - - - - - - - - - - -X 17 CONFIDENTIAL 18 19 Videotaped deposition of FRANCIS PEARN taken at the offices of 20 Boies Schiller Flexner LLP, 55 Hudson Yards, New York, New York 10001, before 21 Clifford Edwards, Certified Shorthand Reporter, and Notary Public in and for the 22 State of New York, on March 29, 2023, at 9:47 a.m. EDT. 23 24 25 Case 1:22-cv-10904-JSR Document 263-4 Filed 08/07/23 Page 2 of 3 Confidential - Francis Pearn Golkow Litigation ServicesPage 137 1 2 a human trafficking activity, they would be able 3 to see that. 4 BY MS. BOGGS: 5 Q Did JPMorgan's assessment of its risks 6 relating to human trafficking materially change 7 from 2006 to 2019? 8 MR. BUTTS: Objection. Form. 9 You may answer if you are able. 10 A It evolved. Like, as our program did. 11 As more work was done with other institutions, 12 with law enforcement, with global bodies such as 13 the Wolfsberg organization, which we are a 14 member, the U.S. regulators later in 2014 and 15 again in 2020 put out supplements -- put out 16 supplementary guidance specific around human 17 trafficking. 18 In there they included what they call 19 red flags or types of activities, the term I've 20 been using here, that could be an indicator or 21 indicators of human trafficking. 22 So all of that led to or contributed to 23 our evolving our efforts to identify money -- 24 potential money laundering related to human 25 trafficking. Case 1:22-cv-10904-JSR Document 263-4 Filed 08/07/23 Page 3 of 3