"Available for Actionable Items"
On April 23, 2013, Jeffrey Epstein sent an email to Terje Rod-Larsen, president of the International Peace Institute, and Andrea Pfanzelter, IPI's Vienna director. A potential donor was in play. Epstein's instruction to the two senior officials of a UN-adjacent diplomatic organization was blunt: "andrea should tell him that IPI woudl accept 5 million as a donation and then be availble tor actionable items." 1
IPI is not a shell company. It was founded in 1956, occupies the 4th and 12th floors of 777 United Nations Plaza, and convenes heads of state, WHO directors general, and foreign ministers under a mandate of conflict prevention and multilateral cooperation. 2 Its events have drawn Margaret Chan of the WHO, Chris Elias of the Bill & Melinda Gates Foundation, and representatives of a dozen governments. 3 Its president, Rod-Larsen, had served as the United Nations Under-Secretary-General and Special Envoy to the Middle East, and was one of the architects of the Oslo Accords.
And here was Epstein — at that point a registered sex offender, five years past his Florida conviction — dictating the terms under which this institution would accept money and perform tasks. The CC line included Boris Nikolic, the science advisor to the Bill & Melinda Gates Foundation, linking IPI's operations to Epstein's separate science philanthropy network.
This was not an isolated email. Pfanzelter sent operational reports directly to Epstein, not through Rod-Larsen. 4 When someone was building Epstein's "international website" in February 2013, they asked him: "Am putting in info about the Intl Peace Institute etc. Are there other intl. organizations that you have worked with?" 5 In the matters that appear in the email corpus, Epstein didn't simply support IPI. He directed it.
The question that follows is the question any financial investigator asks: who paid for this?
The $10 Million Vehicle
On October 14, 2015, an entity called BV70 LLC deposited $10,003,000 into the Deutsche Bank account of Gratitude America, Ltd. — a USVI-incorporated 501(c)(3) private foundation at 9053 Estate Thomas, Suite 101, Charlotte Amalie. 6
Gratitude America had existed since April 2012 but had done nothing. Its 990-PF filings for 2012, 2013, and 2014 each reported $1 in total assets. 6 It was a shelf entity — incorporated by Erika Kellerhals, Epstein's USVI attorney, who asked Epstein by email: "Can you provide me with the names of 3 directors for Gratitude America please?" 7 Epstein chose the directors. Richard Kahn became president, Darren Indyke treasurer, Kellerhals secretary, and Epstein himself a director — listed on filings through 2019. 6
The contextual evidence strongly indicates the $10 million came from Leon Black. An email in Epstein's files, with the subject line referencing Leon and the instruction "DO NOT SEND, hand deliver," laid out the financial architecture: "$10m paid today to gratitude america, a 501 c 3, will make last year complete. 20 million paid today ftc. 10 million july 15 5 million sept 30. 5 million jan 1 for all of 16. tax savings paid at 37 percent." 8
Gratitude America was the charitable arm of a larger flow. Black's money, apparently deposited through BV70, turned a payment to Epstein's infrastructure into a tax-deductible contribution. At 37 percent, the tax benefit on $10 million was $3.7 million.
Once funded, Gratitude America disbursed grants that traced the boundaries of Epstein's influence network:
- $525,000 to IPI across four payments from 2017 to April 2019, confirmed by KPMG forensic review — the single largest documented grant recipient. 9 Two payments were labeled "Oslo Play" and "Contribution from Gatitude [sic] America, LTD Oslo Play" — "Oslo Play" being Epstein's internal term for his IPI/Rod-Larsen diplomatic operation. 10
- $650,000 to the Kuhn Foundation in 2017-2018 — Robert Lawrence Kuhn's entity in Pasadena, connected to US-China advisory work. 6
- $225,000 to the Melanoma Research Alliance in 2016 — Leon Black's preferred charity, meaning Black's money flowed through Epstein's foundation and back to Black's own philanthropic interest. 6
- At least $30,000 to Noam Chomsky in 2017, by check to Cambridge, with additional payments documented for a linguistics challenge. 6
- $30,000 channeled through Landon Thomas Jr. — the New York Times financial reporter — to unnamed recipients in August 2017. Thomas forwarded a thank-you note to Epstein: "Needless to say, this is enormous for us and I am tremendously grateful for your efforts." 11
- $35,000 to the Edge Foundation in 2018, connected to John Brockman's science network. 6
Epstein separately orchestrated Leon Black's direct donations to IPI. On May 12, 2015, Epstein emailed Brad Wechsler — connected to Apollo Global Management and Leon Black's inner circle — with two words: "ipi donation?" Wechsler's response: "Don't shoot the messenger: 1. Leon signed letter last week (a fact, I gave it to him to sign and brgt it back to office). 2. Nobody in the office — at this moment — seems to know if the letter was sent or not. 3. A wire transfer for 750k was processed today and IPI shld have by later today or tomorrow." 12 Black had also sent a $200,000 donation letter directly to Rod-Larsen at IPI in December 2014. 13
The KPMG forensic review, conducted December 18, 2020, confirmed total flows from Epstein-controlled entities to IPI of $664,158.88 — five donations plus one reimbursement. 9 Additional flows from Enhanced Education included a $125,000 payment in October 2011 for the "WK Rick Hooper fellowship" and a $14,158.88 reimbursement in March 2014 labeled "L. Summers flight" — a reference to Lawrence Summers, the former Treasury Secretary. 9
Bridge Tax — An intermediary extracts value by connecting parties who cannot, or will not, transact directly. Full analysis →
Evidence: Epstein positioned himself between Black's money and IPI's diplomatic access. Black could have donated directly to IPI — and did, once, for $200,000. But the $10 million went through Gratitude America, where Epstein controlled the board, chose the recipients, and took credit for directing the grants. 12
The Diplomat Who Needed a Guarantor
What did Epstein's money buy? Start with Rod-Larsen.
On September 28, 2014, Thorbjorn Jagland — Secretary General of the Council of Europe, former Prime Minister of Norway, and chairman of the Norwegian Nobel Committee — emailed Epstein about an apartment in Oslo. "I can get a loan up to 7.5 mill kr but I don't get a good one for that amount, need to go to 10 mill. If you can guarantee (very risky) for the rest it would be of help." He proposed "a joint investment which you talked about." 14
A sitting Secretary General of the Council of Europe — the body that oversees the European Court of Human Rights — asking a convicted sex offender to co-sign his mortgage. Jagland knew precisely who Epstein was; the 2008 conviction was public. His contact card in Epstein's files listed him as "Nobel Peace Prize" with his cell phone number. 15
Rod-Larsen's financial dependency ran deeper. In December 2015, Epstein wired $250,000 to Rod-Larsen's account at the United Nations Federal Credit Union. 16 Separately, Epstein funded the purchase of an apartment at Drammensveien 42 in Oslo for Rod-Larsen — a NOK 18 million transaction structured so that Rod-Larsen and an intermediary each contributed NOK 4 million while Rod-Larsen borrowed the remaining NOK 10 million. 17 Norwegian lawyer Kare I. Moljord of Arntzen de Besche handled the property transfer. 18
The personal dependency produced institutional access. On March 26, 2012, Epstein's assistant Lesley Groff coordinated Rod-Larsen's helicopter transport from Puerto Rico to Epstein's private island in the US Virgin Islands. 19 On May 4, 2010, Groff tracked Rod-Larsen's travel schedule for Epstein, noting his title: "Under-Secretary-General of the UN." 20 On June 1, 2018, Groff emailed Rod-Larsen: "Jeffrey is asking if you could please join him and President Lajcak for dinner on Sunday at Jeffrey's home at 7pm." 21 Miroslav Lajcak was at that time the President of the United Nations General Assembly.
Epstein dined with the president of the UN General Assembly, at his townhouse, with the president of IPI as the connector. Multiple documents show repeated Lajcak-Epstein meetings arranged through IPI channels. 222324
The relationship extended beyond diplomacy into what appears to have been actual conflict mediation. In one email, Epstein wrote: "I think to progress what you and terje have spoken about, the rebel leaders are ready to propose a document they woudl like a cease fire, and halt. If you like I can pass on their proposal. THIS IS NOT WHAT I DO. my expertise is only money. . but it seems like your part of the world would like a halt." 25
A convicted sex offender brokering a ceasefire through a former UN envoy. Epstein's own caveat — "this is not what I do, my expertise is only money" — is the most honest sentence in the entire corpus.
Manufactured Dependency — Creating conditions where institutions or individuals become reliant on the actor, converting independence into obligation. Full analysis →
Evidence: Epstein's financial support to Rod-Larsen ($250K wire, below-market apartment) and Jagland (loan guarantee offer) created personal obligations that translated into institutional access — dinner with the UNGA president, IPI event invitations, ceasefire mediation channels. 161421
The Congressional Pipeline
IPI provided access to foreign governments and the UN diplomatic establishment. The Humpty Dumpty Institute provided access to the United States Congress.
HDI — smaller than IPI by an order of magnitude, with annual revenues of $400,000 to $1.5 million compared to IPI's $5 to $12 million — operated at the intersection of Congress and the United Nations. 26 It organized 52 or more congressional delegations to countries including Azerbaijan, Bahrain, Turkey, Cyprus, and various UN events. 27 Its Congressional Advisory Board listed 33 current and former members of Congress. 28
The Epstein connection ran through Jeffrey's brother. On April 2, 2014, Mark Epstein emailed Jeffrey: "You remember Gene, the black guy that's worked for me for decades. On Monday I hosted a reception here for about 40 people. 15 were members of the Black Congressional Caucus. (They came to NY to attend a Humpty Dumpty program at the UN)." 29
Mark Epstein — a real estate developer, not a diplomat — personally hosted 15 members of the Congressional Black Caucus at a reception tied to HDI's UN program. HDI Director Amir Dossal separately co-hosted a UN event with Ghislaine Maxwell. 30 The organizational boundary between HDI and the Epstein network was permeable.
HDI's more recent activities add another dimension. Since 2017, HDI partnered with China's Taihe Institute, reportedly hosting People's Liberation Army-affiliated fellows in programs that facilitated engagement between the US Congress and Chinese military and governmental officials. 31 An organization that facilitated access for both the Epstein network and PLA officials — with no registration under either FARA or the Lobbying Disclosure Act. 3233
Kellerhals, meanwhile, bridged both networks. Epstein's USVI attorney was on Capitol Hill herself. On March 14, 2018, she emailed Groff: "I am in some meetings on the Hill — which will take up most of my day." 34 Her Federal Election Commission records show over $18,000 in political contributions, with more than $9,000 directed to Stacey Plaskett — the USVI's sole delegate to Congress. 35 Kellerhals simultaneously served as secretary and treasurer of Gratitude America, registered agent through Business Basics VI, and Epstein's primary USVI attorney. 3637
Every entity in this infrastructure — IPI, HDI, Gratitude America, Business Basics VI — shared a characteristic: none of them registered under the Foreign Agents Registration Act or filed lobbying disclosures under the Lobbying Disclosure Act.
The Regulatory Void
The Foreign Agents Registration Act, enacted in 1938, requires anyone who acts "at the order, request, or under the direction or control of a foreign principal" to register with the Department of Justice and disclose their activities, compensation, and political contacts. 38 The statute covers not just spies but lobbyists, public relations firms, and anyone who represents foreign governmental interests to the US government.
We searched the FARA database for every organization and person in this network. Fourteen searches. Zero registrations.
No FARA registration for IPI — which received funding from multiple foreign governments, was led by a Norwegian diplomat, and facilitated contact between foreign officials and US policymakers. No registration for HDI — which organized congressional delegations to foreign countries. No registration for Gratitude America. No registration for Rod-Larsen, despite his role as intermediary between foreign governments and US officials. No registration for Ehud Barak, despite extensive US activities through Carbyne and Toka as a former head of state designated as a Politically Exposed Person in international compliance databases. 39 No registration for any entity in the network.
Similarly, no lobbying disclosures under the LDA. Not for IPI, which maintained a Congressional Advisory Board of 33 members. Not for HDI, which organized congressional travel. Not for Gratitude America, which funded both.
FARA provides an exemption for "bona fide religious, scholastic, academic, or scientific pursuits" under 22 U.S.C. 613(e). IPI or HDI might claim this exemption — but there is no record that they ever sought it, and the exemption has never been tested against organizations whose primary function was brokering government-to-government contact with funding directed by a private individual.
The contrast with Elliott Broidy is instructive. Broidy — Republican mega-donor, former RNC Deputy National Finance Chair — pled guilty on October 20, 2020, to conspiracy to violate FARA. 40 His offense: acting as an unregistered agent of foreign governments, lobbying the Trump administration on behalf of Malaysian and Chinese interests, working with intermediary George Nader to influence US policy. President Trump pardoned him on January 20, 2021, before sentencing. As documented in our Gulf analysis, Epstein was directly involved in Broidy's representation, discussing his case with Kathy Ruemmler. 41
Broidy's conduct — back-channel foreign-government influence on US policymakers without disclosure — shares core structural features with what IPI, HDI, and their associated actors performed. The critical distinction: Broidy used private companies (Circinus LLC, Broidy Capital Management). IPI and HDI used 501(c)(3) nonprofits.
Broidy had a formal LDA lobbying apparatus for his domestic interests — seven filings through Ogilvy Government Relations in 2007-2008, reporting $380,000 in the first year alone. 42 He disclosed his domestic lobbying. He disclosed nothing about his foreign influence work. Some actors in this same ecosystem did register: Stonington Strategies (FARA Reg. #6458) and Muzin Capitol Partners (FARA Reg. #6414) registered as agents of the Embassy of Qatar, both at 800 Stonington Road, Silver Spring, Maryland. 4344 These entities connect directly to Broidy through the Broidy v. Reaboi litigation. 45
That some actors in the influence ecosystem registered — and others, performing comparable functions, did not — suggests the nonprofit structure isn't just a coincidence. It's the mechanism.
Jurisdictional Arbitrage — Exploiting gaps between regulatory systems that each cover part of an activity but none covers all of it. Full analysis →
Evidence: IPI Vienna was established as an Austrian "Verein" in 2015 to "facilitate US donations to IPI Vienna directly" 46 — adding a European entity to a network that already spanned USVI incorporation (Gratitude America), New York operations (IPI at 777 UN Plaza), and 501(c)(3) tax exemption. No single regulator can see the whole structure.
After the Arrest
On July 6, 2019, Jeffrey Epstein was arrested at Teterboro Airport.
Eighteen days later, on July 24, a wire transfer of $7,112,268.98 arrived in Gratitude America's Deutsche Bank account. The next day, July 25, another $816,765.69. 47 Nearly $8 million moved into the foundation within three weeks of the arrest. The transfers appear to be internal account consolidations, possibly liquidating positions from other Epstein-controlled accounts into the nonprofit's account.
The entity then froze. Gratitude America's 990-PF filings for 2020, 2021, and 2022 each report the same figure: $8,175,884 in total assets, $0 in revenue (beyond the statutory $1), $0 in grants. 6 The foundation was involuntarily dissolved by the USVI on October 28, 2024, for failure to file annual reports. 36 What happens to the $8.175 million is unresolved.
IPI's financial trajectory tells a parallel story of institutional damage. At its peak in 2014, IPI held $16.4 million in assets on $11.9 million in revenue. 48 After the Epstein revelations, revenue crashed 58 percent in 2020 — to $3.9 million — and assets have declined to $6.9 million by 2023, the lowest point in available filings. 48 Over the decade from 2014 to 2023, IPI's assets fell by nearly $9.5 million. The Epstein connection appears to have permanently damaged IPI's donor base.
In December 2022, a False Claims Act whistleblower case was filed against IPI in the District of Minnesota. 49 The False Claims Act applies when an entity defrauds the federal government — the filing implies IPI may have received federal funds while misrepresenting its activities or relationships. The case remains active. 49
The IPI Vienna entity that Pfanzelter directed — the Austrian Verein created to "facilitate US donations to IPI Vienna directly" 46 — was part of the architecture Epstein oversaw. Whether that architecture, and the representations IPI made to obtain federal funding, withstand scrutiny under the False Claims Act is now a question for the courts.
What We Don't Know
The $10 million deposited into Gratitude America came from BV70 LLC. Deutsche Bank's compliance team could not complete KYC review on this entity. Stewart Oldfield, Epstein's Deutsche Bank relationship manager, contacted "brad" — likely an advisor — three to four times about the BV70 documentation with no response, eventually warning that the bank would "need to begin a process to transfer or close this account." 50 We do not know BV70's jurisdiction of incorporation, its officers, or its ownership structure beyond the inference from context that it was a Leon Black vehicle.
Gratitude America's 990-PF filings for 2016, 2017, and 2018 are available only as PDFs, not machine-readable data. The grant schedules in these filings — which would show exactly who received money during the foundation's most active years — have not been fully extracted. The documented grants total approximately $1.65 million of the $10 million endowment. Where the remainder went — or whether it remains in the frozen $8.175 million — is not established.
We do not know Rod-Larsen's compensation from IPI during the years of Epstein's influence. IPI's 990 filings report executive compensation, but we have not isolated Rod-Larsen's specific figures from the available data.
HDI's congressional delegation itineraries — who traveled, where, when, and who funded the trips — are not in the released document corpus. HDI's paper trail in the DOJ materials is thin: one result in DOJ Vol 11, zero in LMSBAND, zero in the unified email corpus. Whether this reflects careful operational security or simply a weaker connection to Epstein's email infrastructure is unclear.
We do not know whether IPI or HDI ever considered FARA registration, sought legal advice on the question, or consciously relied on the 613(e) academic exemption. The absence of registration could reflect ignorance, deliberate avoidance, or a good-faith legal determination that the exemption applied. The distinction matters for any assessment of intent, but the documents do not resolve it.
What the documents do establish is that three 501(c)(3) organizations — IPI, HDI, and Gratitude America — operated as a parallel diplomatic corps. One brokered between foreign governments and the UN establishment. One brokered between foreign governments and the US Congress. One funded both, with money from a billionaire, directed by a convicted sex offender, through a USVI shell entity that Deutsche Bank's own compliance team could not verify. None registered as foreign agents. None filed lobbying disclosures. And the only person in the broader influence network who was prosecuted for this kind of conduct — Elliott Broidy — was pardoned before sentencing, having made the mistake of using private companies instead of nonprofits.
- 1.EFTA02520689
- 2.ACRIS 2017021700466001
- 3.EFTA02702398
- 4.EFTA02708972
- 5.EFTA02723098
- 6.990 EIN 660789697
- 7.EFTA02550717
- 8.EFTA02504960
- 9.KPMG: IPI
- 10.EFTA02652208
- 11.EFTA02366490
- 12.EFTA02364954
- 13.EFTA02705181
- 14.EFTA02344136
- 15.EFTA02294377
- 16.Finding #105
- 17.Finding #102
- 18.Finding #113
- 19.EFTA02304575
- 20.EFTA02424447
- 21.EFTA02246816
- 22.EFTA02225411
- 23.EFTA02226954
- 24.EFTA02532007
- 25.EFTA02534000
- 26.990 EIN 134028567
- 27.Finding #130
- 28.Finding #124
- 29.EFTA01929259
- 30.Finding #114
- 31.Finding #122
- 32.Finding #388
- 33.Finding #410
- 34.EFTA02239485
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- 36.USVI 582530
- 37.USVI 582110
- 38.22 U.S.C. 611(c)(1
- 39.OpenSanctions Q125731
- 40.Finding #1390Sources: CourtListenerView source record
- 41.Finding #941
- 42.LDA: Broidy Capital
- 43.FARA #6458
- 44.FARA #6414
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- 46.EFTA02505644
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