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Case 1:23-cv-03903-JSR Document 26-1 Filed 07/06/23 Page 1 of 50
EXHIBIT 1
Case 1:23-cv-03903-JSR Document 26-1 Filed 07/06/23 Page 2 of 50
U.S. Department of Justice
United States Attorney
Southern District ofNew York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York /0007
January 6, 2014
John F. Savarese, Esq.
Stephen R. DiPrima, Esq.
Emil A. Kleinhaus, Esq.
Wachtell, Lipton, Rosen & Katz
51 West 52n Street
New York, New York 10019
Steven R. Peikin, Esq.
Sullivan & Cromwell LLP
125 Broad Street
New York, New York 10004
Re: JPMorgan Chase Bank, N.A. - Deferred Prosecution Agreement
Dear Messrs. Savarese, DiPrima, Kleinhaus, and Peikin:
Pursuant to our discussions and written exchanges, the Office of the United States
Attorney for the Southern District of New York (the "Office") and defendant JPMorgan Chase
Bank, N.A. ("JPMorgan" or the "Bank"), under authority granted by its Board of Directors in the
form of a Board Resolution (a copy of which is attached hereto as Exhibit A), hereby enter into
this Deferred Prosecution.Agreement (the "Agreement").
The Criminal Information
1. JPMorgan consents to the filing of a two~count Information (the
"Information") in the United States District Court for the Southern District of New York (the
"Court"), charging JPMorgan with failure to maintain an effective anti-money laundering
program, in violation of Title 3 I, United States Code, Sections 5318(h) and 5322(a) and Title 12,
Code of Fede
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