Jay Clayton
Clayton's career spans Wall Street legal practice, federal regulatory leadership, private equity governance, and federal prosecution. He moved from advising major banks at Sullivan & Cromwell to chairing the SEC, then joined Apollo's board during its post-Epstein governance restructuring, and now leads the SDNY office responsible for the Epstein financial investigation. Each position corresponds to an institutional node in the broader investigation.
Jay Clayton is an American attorney who has held successive positions at the intersection of financial regulation and the Epstein investigation. He served as Chairman of the Securities and Exchange Commission (2017–2020), Lead Independent Director and Non-Executive Chairman of Apollo Global Management (2021–2025), and United States Attorney for the Southern District of New York (SDNY) beginning in April 2025 by appointment of President Trump. As a partner at Sullivan & Cromwell (1993–2017), Clayton advised Goldman Sachs on its TARP bailout, counseled Bear Stearns during its 2008 sale to JPMorgan Chase, and represented major private equity firms including Apollo. On January 19, 2017, Richard Kahn, a member of Epstein's inner circle, forwarded an article about Clayton's SEC nomination to Epstein 1, indicating that Epstein's network was tracking the appointment and its implications for the private equity industry.
Clayton's appointment to lead SDNY placed him atop the office responsible for investigating Epstein's financial network. His prior institutional relationships overlap with multiple subjects of that investigation. He served as Apollo board chairman while the firm's founder, Leon Black, was publicly associated with $158 million in consulting fees paid to Epstein. He personally represented Reid Hoffman at Sullivan & Cromwell; Hoffman is now a named target in Attorney General Pam Bondi's directed Epstein investigation. His wife Gretchen Butler Clayton was a Goldman Sachs Vice President for 17 years, and he advised both Goldman Sachs and JPMorgan during his private practice. Attorney General Bondi directed Clayton to investigate Epstein ties to Bill Clinton, Larry Summers, Reid Hoffman, and JPMorgan—a scope that does not include Republican-aligned figures or Clayton's own institutional relationships 2. Within months of his appointment, Maurene Comey, the prosecutor who led the Epstein and Ghislaine Maxwell cases, was fired from SDNY 2.
An earlier effort to place Clayton at SDNY had failed. In June 2020, Attorney General William Barr announced that Clayton would replace Geoffrey Berman as SDNY US Attorney while Berman was actively overseeing the Epstein prosecution, the Goldman Sachs 1MDB criminal probe, a JPMorgan investigation, and a Giuliani investigation 3. Berman refused to resign; Trump fired him on June 20, 2020. Clayton withdrew from the nomination, Audrey Strauss became acting USA, and Ghislaine Maxwell was arrested twelve days later. The 2025 appointment achieved the same outcome that the 2020 effort did not: an attorney whose career was built advising Epstein-linked financial institutions now leads the office investigating those institutions.
Key Relationships
At Sullivan & Cromwell, Clayton served on the Management Committee while advising financial institutions that later became subjects in the Epstein investigation. The firm's representation of Bear Stearns during its March 2008 sale to JPMorgan Chase placed Sullivan & Cromwell on the opposite side of the transaction from Epstein, who held $55.7 million in Bear Stearns stock and lost $22.6 million in the collapse 4. As counsel to the acquiring entity, the firm would typically have had access to major shareholder data during the engagement.
In February 2021, Clayton joined the Apollo Global Management board as Lead Independent Director, becoming Non-Executive Chairman after Leon Black stepped down in March 2021. The appointment coincided with a governance restructuring following the Dechert report that detailed Black's $158 million in payments to Epstein. Board compensation totaled over $630,000 annually, including cash fees and restricted stock units 5. Bloomberg reported that Apollo increased board member pay by at least 20 percent after the Epstein-related governance changes 6. Apollo described Clayton's appointment as providing independent board oversight during this transition.
LittleSis network data identifies Clayton as a golf partner of Donald Trump 7. Trump nominated Clayton as SEC Chairman in 2017, sought to place him at SDNY in 2020, and appointed him to the position in 2025. Clayton also maintained a connection to William Barr, who initiated the 2020 SDNY effort and whose own relationships with Epstein-linked institutions are documented separately.
Financial Activity
Clayton's family holds assets through structures that drew conflict-of-interest scrutiny during his SEC confirmation. His wife Gretchen and children hold stakes in WMB Holdings through family trusts. WMB Holdings shares an address with Corporation Service Company at 2711 Centerville Road, Suite 400, Wilmington, Delaware—a registered agent address used by thousands of business entities 8. Clayton's father-in-law, Daniel Butler, served as CEO of Corporation Service Company from 1975 to 1998. In March 2017, Public Citizen requested a Senate Banking Committee investigation regarding potential 18 U.S.C. § 208 conflicts of interest related to Clayton's executive branch service 8. Estimated annual dividends exceed $4 million, with approximately $200 million in assets based on a 2 percent yield calculation.
Epstein's Bear Stearns stock positions intersected with Clayton's institutional role at Sullivan & Cromwell. Epstein purchased 300,000 Bear Stearns shares at $97.21 on November 30, 2004, and additional shares at $106.26 on July 14, 2005, for a total purchase cost of $55,728,004.33. During the March 2008 collapse, Epstein sold in tranches: 73,650 shares at $32.51 on March 14, 2008; 20,000 at $34.93; 100,000 at $32.00 on the same day; and a final 100,000 at $3.35 on March 17, 2008—the day of the JPMorgan acquisition 4. Total sales proceeds were $33,079,369.60, producing a net loss of $22,648,634.73. Epstein subsequently received a $3.7 million BSC Stock Drop Action settlement with JPMorgan, with proceeds flowing through Darren Indyke's attorney trust account 9.
A ProPublica financial disclosure filed under "Walter Joseph Clayton" lists net worth between $32 million and $117 million. Holdings include Apollo Global Management, Millennium Management, Fireblocks, Coinbase Asset Management, Electric Capital Partners, and a continuing Senior Policy Advisor role at Sullivan & Cromwell 10. Several of these holdings are in the crypto and digital asset sector, which was a focus of regulatory debate during Clayton's SEC tenure. Political contributions documented in LittleSis entity 254763 span both parties: Chuck Schumer ($2,000, December 2021), Mike Crapo ($2,000, December 2021—ranking member of Senate Banking), Jim Himes ($2,000, January 2022—House Financial Services), Kevin McCarthy ($2,000, January 2022), WinRed ($5,000), French Hill ($2,000), John Kennedy ($2,000), and Thomas Kean Jr ($1,000) 7.
Legal Proceedings
On June 19, 2020, Attorney General William Barr announced Clayton would replace Geoffrey Berman as SDNY US Attorney. At the time, SDNY was investigating Epstein's co-conspirators, Goldman Sachs' 1MDB criminal exposure, JPMorgan's relationship with Epstein, and Rudy Giuliani. Berman refused to resign; President Trump fired him on June 20, 2020 3. Clayton withdrew from the nomination. Audrey Strauss became acting USA, and Ghislaine Maxwell was arrested on July 2, 2020—twelve days later.
Clayton's appointment to the same position was completed in April 2025, with judicial confirmation on August 18, 2025. Attorney General Pam Bondi directed Clayton to investigate Epstein ties to Bill Clinton, Larry Summers, Reid Hoffman, and JPMorgan 2. The directed scope as publicly reported does not include Republican-aligned figures or Clayton's own prior institutional relationships. Maurene Comey—the prosecutor who led the Epstein and Ghislaine Maxwell cases—was subsequently fired from SDNY, with prosecutors reportedly "bewildered and on edge about political interference" 2.
Four specific institutional relationships create potential conflict-of-interest questions under 28 U.S.C. § 455 and DOJ conflict policies: (1) Clayton served as Apollo board chairman while Leon Black's $158 million in payments to Epstein were under scrutiny; (2) he personally represented Reid Hoffman at Sullivan & Cromwell, and Hoffman is a named investigation target; (3) his wife held a 17-year career as Goldman Sachs Vice President, and Goldman is a subject of related investigations; (4) he advised JPMorgan during the Bear Stearns acquisition, and JPMorgan is a named target. Whether disclosure or recusal has occurred in any of these areas is not publicly known.
Intelligence Activity
Epstein's network tracked Clayton's career before his SEC appointment. On January 19, 2017—the eve of Trump's inauguration—Richard Kahn, who served as executor of Epstein's will and trustee of Gratitude America, forwarded a Seeking Alpha article to Epstein about Clayton's nomination to lead the SEC 1. The article by Stephen Alpher noted that "attorney Jay Clayton—who has advised on numerous major P-E deals—to lead the SEC" alongside Wilbur Ross (Commerce) and Steve Schwarzman (Policy Forum chair). It also listed "Other players: OAK, APO, FIG, ARES"—APO being Apollo Global Management's ticker symbol. This communication occurred four years before Clayton joined Apollo's board.
Stephen Cutler's career shows a comparable trajectory between SEC enforcement and Wall Street. Cutler served as SEC Enforcement Director from 2001 to 2005 before becoming JPMorgan General Counsel, where he managed Epstein's BSC settlement while Clayton was at Sullivan & Cromwell advising Bear Stearns 11. Both subsequently became involved with aspects of the Epstein investigation from different positions—Clayton as SDNY US Attorney, Cutler as the former JPMorgan General Counsel whose institution is a named investigation target.
Kathryn Ruemmler, who served as Epstein's lawyer, trustee, and successor executor with over 201 documented emails to Epstein, monitored Sullivan & Cromwell personnel moves and reported them to Epstein. A December 2017 email discussed Karen Seymour's move from Sullivan & Cromwell to Goldman 12. Clayton was on Sullivan & Cromwell's Management Committee at the same time. No direct Clayton-Ruemmler communication has been identified, and the extent to which Epstein's network tracked individual Sullivan & Cromwell partners beyond Seymour has not been established.
All Connections
12 total
All Connections
12 totalClayton became Apollo Lead Independent Director Feb 2021 then Non-Executive Chairman after Black stepped down Mar 2021. Board position created as governance overhaul after Dechert report exposed Black 158M+ payments to Epstein.
Clayton represented Hoffman personally at Sullivan+Cromwell. Hoffman now named target in Bondi Epstein investigation directed to Clayton at SDNY. Direct conflict of interest.
Clayton advised Goldman at S+C on TARP bailout and Berkshire Hathaway investment during 2008 crisis. Wife Gretchen was Goldman VP 17 years.
Trump nominated Clayton SEC Chair 2017. Tried to install as SDNY USA June 2020 replacing Berman. Golf partners per LittleSis. Installed as SDNY USA April 2025.
Barr announced Clayton replacing Berman as SDNY USA June 19 2020 while Berman oversaw Epstein case and Goldman and JPM criminal probes. Berman refused. Trump fired him June 20. Clayton withdrew.
Clayton advised Bear Stearns on its fire sale to JPMorgan in 2008 at Sullivan+Cromwell. JPM is a named target in Bondi Epstein investigation that Clayton now leads.
S+C advised Bear Stearns on JPM fire sale March 2008. Clayton on S+C Management Committee. Epstein worked at Bear Stearns 1976-1981 under Ace Greenberg. Epstein held 55.7M in BSC stock and lost 22.6M in collapse. S+C would have had access to major shareholder data during the acquisition.
Barr attempted to install SEC Chairman Clayton as SDNY USA to replace Berman (Jun 2020). Clayton was Sullivan & Cromwell partner who had represented Deutsche Bank (Epstein's banker). Wall Street on Parade: 'Barr Fires Top Prosecutor Tries to Replace Him with Banks Former Lawyer.' Clayton withdrew after Berman firing controversy. The attempt to place DB's former lawyer atop SDNY — which was investigating Epstein's DB accounts — is a significant structural connection.
Clayton at S+C advised Bear Stearns on JPM fire sale. Staley at JPM then managed Epstein BSC settlement and forwarded internal JPM legal chain to Epstein. Both later faced Epstein-related consequences: Clayton to Apollo board then SDNY USA, Staley forced out of Barclays over Epstein ties.
Both SEC-to-Wall-Street revolving door. Clayton: S+C then SEC Chair. Cutler: SEC Enforcement Director 2001-2005 then JPM General Counsel. Cutler managed Epstein BSC settlement at JPM while Clayton was at S+C which had advised Bear Stearns. Cutler is now the one whose former role (SEC oversight) Clayton occupies at SDNY.
Ruemmler tracked Sullivan+Cromwell personnel moves and reported to Epstein. Dec 2017 email about Karen Seymour S+C to Goldman. Clayton was S+C partner on Management Committee at same time. No direct Clayton-Ruemmler communication found but shared S+C institutional nexus.
No direct communication found. But Epstein inner circle member Richard Kahn forwarded article about Clayton SEC nomination to Epstein Jan 19 2017. Clayton later joined board of Apollo whose founder paid Epstein 158M+. Clayton now leads SDNY Epstein investigation with multiple conflicts.
All Findings
13 total
All Findings
13 totalfinancial (5)
BSC SETTLEMENT AND ACCOUNT LABELS: As of Jan 2012, Epstein cash balances included FTC-JPM (Bear Stearns) 3,400,000 and DKI Atty Trust Acct (from BSC Settlement) 3,700,000 and HAZE Trust-JPM 5,100,000. The BSC Settlement funds (3.7M) flowed through Indyke attorney trust account. Bear Stearns account at JPM retained its Bear Stearns label 4 years after acquisition. Epstein had a Bear Stearns/JP Morgan lawyer meeting on May 23, 2011 per Lesley Groff schedule email. Total visible JPM accounts: 11.9M across 3 accounts. Harry Beller provided balances. The BSC settlement was part of the Individual Stock Drop Action class action per JPM internal emails.
WMB HOLDINGS: Clayton wife Gretchen and children hold stakes in WMB Holdings through family trusts. WMB Holdings parent shares address with Corporation Service Company at 2711 Centerville Road Suite 400 Wilmington DE. Estimated 4M+ annual dividends, approx 200M in assets based on 2pct yield calculation. CSC is registered agent for thousands of businesses some linked to Panama Papers. Clayton father-in-law Daniel Butler was CEO of CSC 1975-1998. Public Citizen requested Senate Banking Committee investigation March 2017. Potential 18 USC 208 conflict re executive branch.
Apollo board compensation for Clayton: K annual cash fee plus initial K in restricted stock units covering first 3 years plus K RSU each subsequent year. By 2024 proxy: ,375 cash + ,898 stock + ,500 other = ,773 total. Bloomberg reported Apollo lifted board member pay at least 20 percent after Epstein fallout in Feb 2021. Clayton was appointed Lead Independent Director same month, became Non-Executive Chairman when Leon Black stepped down March 2021.
BEAR STEARNS STOCK POSITIONS: Epstein held massive Bear Stearns stock position. Purchased 300,000 shares at 97.21 on 11/30/04 and additional shares at 106.26 on 07/14/05. Total purchase cost 55,728,004.33 (55.7M). Sold in tranches including 73,650 shares at 32.51 on 03/14/08, 20,000 at 34.93, 100,000 at 32.00 on 03/14/08, and final 100,000 at 3.35 on 03/17/08 (the JPM fire sale day). Total sales proceeds 33,079,369.60. NET LOSS 22,648,634.73. Clayton firm Sullivan+Cromwell was advising Bear Stearns on the JPM acquisition that destroyed this position.
ProPublica Trump Team Financial Disclosure: Jay Clayton (filed as 'Walter Joseph Clayton') serving as SDNY US Attorney. Net worth $32M-$117M. Previously undocumented holdings include: Millennium Management, Fireblocks, Coinbase Asset Management, Electric Capital Partners, CNBC. Also holds Apollo Global Management (chairman), Sullivan & Cromwell (Sr. Policy Advisor). Crypto/digital asset holdings (Fireblocks, Coinbase, Electric Capital) are notable given his SEC chairmanship during key crypto regulation debates.
relationship (1)
Jay Clayton appointed to Apollo board as Lead Independent Director effective March 1, 2021 (8-K filed Feb 18). Compensation: base K + K LID fee + K per committee + K per committee chair. Initial RSU K (3yr vest), annual RSU K. Also office space + admin. Appointed Non-Executive Chairman March 21, 2021 when Black stepped down. 2021 total comp: ,408 (,528 cash + ,881 stock). Post-Athene merger became Non-Exec Chair of AGM. Serves as Chair of Nominating/Corporate Governance Committee.
legal (2)
BERMAN FIRING June 2020: AG Barr announced June 19, 2020 that Clayton would replace Geoffrey Berman as SDNY US Attorney. Berman was overseeing Epstein prosecution, Goldman Sachs 1MDB criminal probe, JPMorgan investigation, and Giuliani investigation. Berman refused to resign. Trump fired Berman June 20. Clayton withdrew from nomination. Audrey Strauss became acting USA. Ghislaine Maxwell arrested July 2, 2020 -- two weeks after Berman firing. Wall Street on Parade headline: As Goldman Sachs and JPMorgan Face Criminal Probes Barr Fires Top Prosecutor Tries to Replace Him with Banks Former Lawyer Jay Clayton.
SDNY US ATTORNEY 2025 AND EPSTEIN PROBE: Clayton finally installed as SDNY US Attorney April 2025 by Trump (judges confirmed Aug 18 2025 after Senate stalled). AG Pam Bondi directed Clayton to investigate Epstein ties to Democrats specifically: Clinton, Summers, Reid Hoffman, JPMorgan. CONFLICTS: (1) Clayton was Apollo board chairman -- Leon Black paid Epstein 158M+, (2) Clayton represented Reid Hoffman at S+C -- Hoffman is named investigation target, (3) wife Gretchen was Goldman VP 17 years, (4) Clayton advised Goldman and JPM at S+C. Maurene Comey (Epstein/Maxwell prosecutor) was fired from SDNY. Prosecutors reportedly bewildered and on edge about political interference.
intelligence (4)
SYNTHESIS: BEAR STEARNS STRUCTURAL NODE. Clayton at Sullivan+Cromwell advised Bear Stearns on its fire sale to JPMorgan March 2008. Epstein lost 22.6M on 55.7M of Bear Stearns stock in this collapse. JPMorgan (via Jes Staley and General Counsel Stephen Cutler, former SEC Enforcement Director) then negotiated a BSC Stock Drop Action settlement with Epstein. Settlement proceeds (3.7M) went through Indyke trust account. This means Clayton firm was on the opposite side of the table from Epstein in one of the largest financial events of Epstein life. S+C was counsel to the entity that destroyed 22.6M of Epstein wealth. The institutional knowledge S+C gained about Bear Stearns clients and accounts during this engagement would have included awareness of Epstein as a major shareholder. Clayton was on S+C Management Committee. Bear Stearns was also where Epstein worked 1976-1981 under Ace Greenberg -- his entire financial career traces back to this institution.
CORPUS HIT: Richard Kahn forwarded Seeking Alpha article about Jay Clayton's SEC nomination to Jeffrey Epstein on Jan 19, 2017 (inauguration eve). Article by Stephen Alpher notes 'attorney Jay Clayton — who has advised on numerous major P-E deals — to lead the SEC' alongside Wilbur Ross (Commerce) and Steve Schwarzman (Policy Forum chair). Also mentions 'Other players: OAK, APO, FIG, ARES' — APO is Apollo. This confirms Epstein's inner circle was tracking Clayton's appointment and its implications for the PE industry.
SYNTHESIS: REVOLVING DOOR PATTERN. Clayton career maps a textbook regulatory capture arc: (1) S+C partner advising Goldman JPM and major PE firms 1993-2017, (2) SEC Chairman 2017-2020 with no enforcement against Epstein-linked financial institutions, (3) June 2020 Barr tries to install him at SDNY replacing prosecutor overseeing Epstein case -- fails, (4) Feb 2021 joins Apollo board 630K+/yr -- the firm whose founder paid Epstein 158M+, (5) April 2025 Trump finally installs him at SDNY. Bondi directs him to investigate Epstein ties to Democrats specifically. He has conflicts with Reid Hoffman (former client), Goldman (wife worked there 17 yrs), JPM (former client), and Apollo (was board chairman). Maurene Comey (Epstein/Maxwell prosecutor) fired from office. The Epstein investigation is now led by someone with financial ties to multiple investigation targets.
LITTLESIS NETWORK MAP (entity 254763): Positions -- SDNY US Attorney (current), Apollo Lead Independent Director (2021-02-18), SEC Chairman, Sullivan+Cromwell Partner. Business -- counsel to Goldman Sachs, KPMG (re auditor tipped off before regulatory inspection). Social -- golf partner with Donald Trump, friend of Annette Nazareth (former SEC Commissioner). Donations -- Chuck Schumer 2K Dec 2021, Mike Crapo 2K Dec 2021 (Senate Banking ranking), Jim Himes 2K Jan 2022 (House Financial Services), Kevin McCarthy 2K Jan 2022, WinRed 5K, French Hill 2K, John Kennedy 2K, Thomas Kean Jr 1K. Family -- spouse Gretchen Clayton. Education -- UPenn BS Engineering summa cum laude, Cambridge BA/MA Economics Thouron Scholar, UPenn Law JD cum laude.
identity (1)
Jay Clayton career arc: Sullivan+Cromwell partner 1993-2017 Management Committee co-head corporate. SEC Chairman May 2017-Dec 2020. Apollo Lead Independent Director Feb 2021 then Non-Executive Chairman after Black resigned Mar 2021. SDNY US Attorney Apr 2025-present appointed by Trump judges confirmed Aug 2025. At SC advised Goldman on TARP bailout, Bear Stearns on JPM fire sale, Barclays on Lehman, did Alibaba IPO, represented Reid Hoffman. Wife Gretchen Butler Clayton was Goldman VP 17 years resigned on his SEC confirmation.