[V2.0 -- NEW SECTION]
The BNY Mellon Consent Order identifies Kahn and Indyke as "ATTORNEY-1" and "ACCOUNTANT-1" respectively, documenting $378M across 270 wires processed through Bank of New York Mellon accounts. The case was dismissed on January 29, 2026. Senator Wyden requested SARs related to these transactions.
HBRK Associates Inc. was founded on August 29, 2008 (EIN 30-0503838) and registered in New York. PitchBook classifies it as a "single-family office." The name HBRK derives from the initials of Harry Beller and Richard Kahn -- Beller appears in EFTA01416771 as Authorized Signatory on Neptune LLC and Trustee of Butterfly Trust. HBRK registered as agent for Coatue Enterprises LLC (EFTA01265973), a Philippe Laffont entity.
The FBI designated Kahn as a co-conspirator in 2019. An 86-page SDNY co-conspirator memo (December 19, 2019) analyzed potential charges. The DOJ has never publicly questioned Kahn under oath. Senator Wyden wrote to DOJ/FBI in December 2025 demanding an explanation for why Kahn was never charged despite the co-conspirator designation.
Kahn was subpoenaed by the House Oversight Committee. His deposition was scheduled for February 25, 2026.
The Senate Finance Committee investigation established the $170M total payment figure. The investigation found that approximately $100M was transferred without any written contract or service agreement. The written agreement (dated February 13, 2013) post-dates the first payment. Epstein represented he "generally charged clients $40 million per year" -- a characterization inconsistent with standard advisory fees. The IRS never audited any of these transactions despite their extraordinary size and the publicly known criminal history of the recipient.
[GRADE D -- Unconfirmed name match] A BVI entity named "HBRK Equity Ltd" appears in the Panama Papers / ICIJ database. The name match with HBRK Associates Inc. is noted but NOT confirmed as belonging to Richard Kahn. This requires independent corroboration per Law 5.
WHAT THIS SHOWS AND DOES NOT SHOW: Web-corroborated findings establish the broader legal and financial context around Kahn's role. The co-conspirator designation, congressional subpoena, and Wyden letter demonstrate active federal and legislative scrutiny. The Leon Black Senate investigation provides the $170M total and documents the absence of IRS oversight. The HBRK Equity Ltd Panama Papers match is noted as an unconfirmed lead requiring further investigation. Web sources are cited with publication dates where available and are clearly distinguished from primary EFTA/DOJ evidence.