Southern Country International Ltd

Southern Country International Ltd began its corporate life under the name Financial Strategy Group Ltd. The Articles of Incorporation ¹, filed with the USVI Division of Corporations, show incorporators Erika A. Kellerhals, Brett A. Geary, and Nicole Miller, with Business Basics LLC (the precursor name to Business Basics VI LLC) as registered agent. ¹ Authorized capital was set at 1,000,000 shares at $5.00 par value, with a minimum of $500,000 required to commence operations. ¹ The entity was assigned USVI Corporation Number 584624. ¹ A Certificate of Good Standing issued July 9, 2018 by the USVI Office of Lieutenant Governor confirms the renaming: “the corporation known as SOUTHERN COUNTRY INTERNATIONAL LTD. Formerly: FINANCIAL STRATEGY GROUP LTD.” ¹ The timing of the renaming — occurring in mid-2018, after Deutsche Bank had begun closing Epstein accounts — is documented but the direct cause of the rename is not established in the record.

A parallel Florida entity, Financial Strategy Group, Inc. (FL SunBiz P93000087814, EIN 65-0464008), was incorporated December 27, 1993 at 358 El Brillo Way, Palm Beach, with Epstein as sole officer and registered agent, voluntarily dissolved March 30, 2000. The shared name across a Palm Beach corporation and a USVI entity — which was eventually dissolved and renamed — is consistent with the broader Epstein corporate inventory, where entity names were reused across jurisdictions and managed by the same officers and attorneys.

SCI's formal charter purpose distinguished it from other entities in the Southern Trust Company family. While Southern Trust Company Inc. operated as a private consulting and investment management company, and Southern Financial LLC held domestic accounts, SCI was specifically authorized as an international banking entity under USVI Code Title 9, Chapter 25 — the Economic Development Commission statutory framework. This designation carries regulatory implications: EDC-licensed international banking entities in the USVI operate under specific regulatory oversight and receive associated tax benefits, but they also operate in a structure with limited external visibility relative to mainland U.S. banking institutions.

In September 2015, Richard Kahn and Epstein accountant Jeanne Brennan consulted CPA Alan Dlugash about IRS Form 1120 business activity codes for SCI. Dlugash's written recommendation was explicit: “Alan Dlugash today and he feels strongly that we should use biz activity code 525990 (other financial vehicles) along with Business Activity: Investments Product or Service: Investments Alan believes that if we were to include language that included International Banking it may unnecessarily trigger an audit from IRS task force.” ⁴ The Financial Trust Company, a related Epstein entity, used code 523900 (Other Financial Investment Activities). ⁴ The choice to classify an entity explicitly chartered as an international banking entity under a generic "Other Financial Vehicles" code, rather than a banking-specific code, is a documented tax filing decision made to avoid IRS international banking task force scrutiny. ⁴

SCI's primary known bank account was a FirstBank Puerto Rico commercial checking account at 6100 Red Hook Quarter B3, St. Thomas, USVI 00802, with Darren Indyke as signatory. ² A January 2015 FirstBank statement shows $1,010 in deposits and $1,010 in debits. ⁵ In April 2019 — the same month Charles Schwab accounts were opened for Southern Trust Company, Southern Financial LLC, and SCI under Richard Kahn, with Epstein as beneficial owner and internal control person — SCI became part of the Schwab relationship. Charles Schwab opened an AML investigation of this account cluster, case opened July 8, 2019. ⁶ The Schwab accounts were opened three months before Epstein's July 6, 2019 arrest, during the same period Deutsche Bank was closing his accounts.

SCI remained operationally active after Epstein's death on August 10, 2019. On November 25, 2019 — more than three months after Epstein died — SCI received two payments from the HBRK Associates Neptune LLC account managed by Richard Kahn: one check for $1,000 and one for $3,738. ⁵ The New York Times subsequently reported that Southern Country received millions from the estate in December 2019. Deutsche Bank wire records ⁷ document $1 million transferred on December 23, 2019 within Southern Trust Company accounts during the same post-death period.

A companion entity, Southern Country Opportunity Fund LLC (USVI entity DC0102285), was registered February 21, 2019 — less than five months before Epstein's arrest — with Business Basics VI LLC as registered agent at the Royal Palms Professional Building, Estate Thomas Suite 101. Its stated purpose was listed as “Other, Other.” (USVI Division of Corporations, DC0102285) The entity was in good standing from February 25, 2019 through November 30, 2021, then administratively dissolved December 30, 2021. The formation of Southern Country Opportunity Fund LLC coincided with the opening of Schwab accounts across the Southern family of entities, all occurring as Deutsche Bank was exiting the Epstein relationship.

SCI itself was administratively dissolved, with its last annual report filed in 2019. Gratitude America Ltd, another Epstein USVI entity sharing registered agent and officer infrastructure with SCI, underwent a similar post-death administrative dissolution process and its assets remained frozen at $8.175 million from 2020 through 2022 with zero revenue or expenses, consistent with an estate under active legal investigation.

On March 3, 2020, the USVI U.S. Attorney's Office opened a formal criminal investigation of the Epstein estate and Southern Country International Bank. The USVI AUSA sent an email directly to SDNY U.S. Attorney Geoffrey Berman: “We are opening an investigation of the Jeffrey Epstein estate and Southern Country International Bank in the USVI. The investigation will be worked by FBI and IRS-CI. I wanted to reach out to you, in order to make certain that we are not interfering with any ongoing investigation that your office may have.” Berman responded: “thanks for the heads up. We are looking into aspects of the estate.” ³ By April 2020, the USVI office expected grand jury subpoenas for Epstein's jail calls and related custodial materials.

Internal communications suggest friction in the inter-office coordination. Berman forwarded a direct email from a USVI line AUSA to his staff with the note: “I dont know why this guy continues to email Geoff! Can you see if you can redirect that?” ³ On June 19, 2020, Attorney General Barr announced that Jay Clayton would replace Berman as SDNY U.S. Attorney. Berman refused to resign and was fired June 20. Ghislaine Maxwell was arrested July 2, 2020, two weeks after the Berman dismissal. Whether the USVI SCI investigation was subsumed, deconflicted, or closed following those personnel changes is not established in available records.

The federal referral identified the entity as Southern Country International Bank — using “Bank” rather than the corporate “Ltd” designation — despite the documented 2015 tax classification decision to avoid the entity being identified as a banking institution for IRS purposes. The IRS-CI assignment to the investigation is consistent with the financial focus: post-death asset transfers, estate tax compliance, and the international banking entity structure that Dlugash had advised Kahn to classify under a non-banking activity code in 2015.

SCI was one of 28 Epstein-linked USVI entities sharing Business Basics VI LLC as registered agent or the 9053 Estate Thomas / 6100 Red Hook Quarter B3 addresses. Business Basics VI LLC was registered January 26, 2012, with Erika Kellerhals as resident agent, and served as the central administrative firm for the USVI entity network. The DOJ's entity inventory of Epstein's USVI corporate structure lists SCI alongside Great St. Jim LLC, IGO Company LLC, J. Epstein Virgin Islands Foundation Inc., Jeepers Inc., Laurel Inc., Little St. James LLC, LSJE LLC, Maple Inc., Michelle's Transportation Co. LLC, Nautilus Inc., Southern Trust Company Inc., and Thomas World Air — all managed through the same officer network of Indyke, Kellerhals, and Kahn.

The registered agent address for SCI at the time of incorporation was listed as 9100 Port of Sale Mall Suite 15, St. Thomas ¹ — the original Kellerhals Ferguson law firm address — before operations migrated to the Royal Palms Professional Building. Across this infrastructure, Kellerhals served as secretary and treasurer of Gratitude America Ltd, officer at the J. Epstein VI Foundation, and officer at Enhanced Education, while simultaneously advising Epstein on USVI residency requirements, EDC tax conference language, and dynasty trust legislation. (Findings #332, #338) The degree to which Kellerhals' dual role — as outside counsel and as officer of entities she incorporated — created structural conflicts of interest is a question present in the record but not resolved by available documents.