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 a Sullivan & Cromwell partner who had represented Deutsche Bank, Epstein's banker. Wall Street on Parade described it as 'Barr Fires Top Prosecutor, Tries to Replace Him with Banks' Former Lawyer.' Clayton withdrew after the Berman firing controversy. The effort would have placed Deutsche Bank's former lawyer atop the office then investigating Epstein's Deutsche Bank accounts.
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 moved between SEC and Wall Street roles. Clayton went from Sullivan & Cromwell to SEC Chair; Cutler was SEC Enforcement Director from 2001 to 2005 before becoming JPMorgan General Counsel. Cutler managed Epstein's BSC settlement at JPMorgan while Clayton was at Sullivan & Cromwell, which had advised Bear Stearns. Cutler held the SEC enforcement oversight role that Clayton's SDNY position now parallels.
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)
As of January 2012, Epstein's cash balances included FTC-JPM (Bear Stearns) at 3,400,000, a DKI attorney trust account (from the BSC settlement) at 3,700,000, and a HAZE Trust-JPM account at 5,100,000. The BSC settlement funds (3.7M) flowed through the Indyke attorney trust account, and the Bear Stearns account at JPMorgan retained its Bear Stearns label four years after the acquisition. A Bear Stearns/JP Morgan lawyer meeting appears on Epstein's schedule for May 23, 2011 in a Lesley Groff email, with balances provided by Harry Beller. Total visible JPMorgan holdings came to 11.9M across three accounts. JPMorgan internal emails describe the BSC settlement as part of the Individual Stock Drop Action class action.
Clayton's wife Gretchen and children hold stakes in WMB Holdings through family trusts. The WMB Holdings parent shares an address with Corporation Service Company at 2711 Centerville Road, Suite 400, Wilmington, DE. Annual dividends are estimated at 4M+, with roughly 200M in assets based on a 2 percent yield calculation. CSC is the registered agent for thousands of businesses, some linked to the Panama Papers, and Clayton's father-in-law Daniel Butler was CEO of CSC from 1975 to 1998. Public Citizen requested a Senate Banking Committee investigation in March 2017, citing a potential 18 USC 208 conflict tied to executive branch service.
Clayton's Apollo board compensation comprised a K annual cash fee, an initial K in restricted stock units covering the first 3 years, and a K RSU grant each subsequent year. The 2024 proxy records ,375 cash, ,898 stock, and ,500 other, for ,773 total. Bloomberg reported that Apollo lifted board member pay at least 20 percent after the Epstein fallout in February 2021, the same month Clayton was appointed Lead Independent Director; he became Non-Executive Chairman when Leon Black stepped down in March 2021.
Epstein held a large Bear Stearns stock position. He purchased 300,000 shares at 97.21 on 11/30/04 and additional shares at 106.26 on 07/14/05, for a total purchase cost of 55,728,004.33 (55.7M). He 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 a final 100,000 at 3.35 on 03/17/08 (the JPMorgan fire-sale day). Total sales proceeds were 33,079,369.60, a net loss of 22,648,634.73. Clayton's firm, Sullivan & Cromwell, was advising Bear Stearns on the JPMorgan acquisition that ended this position.
A ProPublica Trump Team financial disclosure lists Jay Clayton, filed as 'Walter Joseph Clayton' and serving as SDNY US Attorney, with a net worth of $32M-$117M. Previously undocumented holdings include Millennium Management, Fireblocks, Coinbase Asset Management, Electric Capital Partners, and CNBC. He also holds Apollo Global Management (chairman) and a Sullivan & Cromwell Senior Policy Advisor role. Several of the disclosed holdings (Fireblocks, Coinbase, Electric Capital) are in the crypto and digital asset sector, which was a focus of regulatory debate during his SEC chairmanship.
relationship (1)
Jay Clayton was appointed to the Apollo board as Lead Independent Director effective March 1, 2021 (8-K filed February 18). His compensation comprised a base of K plus a K LID fee, K per committee, and K per committee chair, an initial RSU grant of K (3-year vest), and an annual RSU of K, along with office space and administrative support. He was appointed Non-Executive Chairman on March 21, 2021 when Black stepped down. His 2021 total compensation was ,408 (,528 cash and ,881 stock). After the Athene merger he became Non-Executive Chair of AGM, and he serves as Chair of the Nominating and Corporate Governance Committee.
legal (2)
On June 19, 2020, AG Barr announced that Clayton would replace Geoffrey Berman as SDNY US Attorney. Berman was at the time overseeing the Epstein prosecution, the Goldman Sachs 1MDB criminal probe, a JPMorgan investigation, and a Giuliani investigation. When Berman refused to resign, Trump fired him on June 20; Clayton then withdrew from the nomination and Audrey Strauss became acting USA. Ghislaine Maxwell was arrested on July 2, 2020, two weeks after the Berman firing. A Wall Street on Parade headline framed the sequence: 'As Goldman Sachs and JPMorgan Face Criminal Probes, Barr Fires Top Prosecutor, Tries to Replace Him with Banks' Former Lawyer Jay Clayton.'
Clayton was installed as SDNY US Attorney in April 2025 by Trump, with judges confirming him on August 18, 2025 after the Senate stalled. AG Pam Bondi directed Clayton to investigate Epstein ties to Democrats specifically: Clinton, Summers, Reid Hoffman, and JPMorgan. The record indicates several conflicts: (1) Clayton was Apollo board chairman while Leon Black's 158M+ in payments to Epstein were under scrutiny; (2) Clayton represented Reid Hoffman at Sullivan & Cromwell, and Hoffman is a named investigation target; (3) his wife Gretchen was a Goldman VP for 17 years; and (4) Clayton advised Goldman and JPMorgan at Sullivan & Cromwell. Maurene Comey, the Epstein and Maxwell prosecutor, was fired from SDNY, and prosecutors were reportedly bewildered and on edge about political interference.
intelligence (4)
Clayton, at Sullivan & Cromwell, advised Bear Stearns on its fire sale to JPMorgan in March 2008. Epstein lost $22.6M on a $55.7M Bear Stearns stock position in the collapse. JPMorgan, through Jes Staley and General Counsel Stephen Cutler (a former SEC Enforcement Director), then negotiated a BSC Stock Drop Action settlement with Epstein, the $3.7M in proceeds passing through the Indyke trust account. Sullivan & Cromwell was therefore counsel to the acquiring side in one of the largest financial events of Epstein's life, opposite him as a major Bear Stearns shareholder. As counsel on the transaction, the firm would typically have had access to shareholder data. Clayton sat on the firm's Management Committee. Bear Stearns was also where Epstein worked from 1976 to 1981 under Ace Greenberg, the institution where his financial career began.
Richard Kahn forwarded a Seeking Alpha article about Jay Clayton's SEC nomination to Jeffrey Epstein on Jan 19, 2017 (inauguration eve). The 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), and also mentions 'Other players: OAK, APO, FIG, ARES' — APO being Apollo. The forward indicates that Epstein's inner circle was tracking Clayton's appointment and its implications for the private equity industry.
Clayton's career traces a sequence connecting financial-sector practice to federal regulation and prosecution: (1) Sullivan & Cromwell partner advising Goldman, JPMorgan, and major PE firms from 1993 to 2017; (2) SEC Chairman 2017-2020, a tenure with no enforcement action against Epstein-linked financial institutions; (3) June 2020, Barr's attempt to install him at SDNY in place of the prosecutor overseeing the Epstein case, which failed; (4) February 2021, appointment to the Apollo board at 630K+/yr, the firm whose founder paid Epstein 158M+; and (5) April 2025, Trump's appointment of him to SDNY. Bondi directed him to investigate Epstein ties to Democrats specifically. The record indicates potential conflicts involving Reid Hoffman (former client), Goldman (where his wife worked 17 years), JPMorgan (former client), and Apollo (former board chairman). Maurene Comey, the Epstein and Maxwell prosecutor, was fired from the office. The result is that the Epstein investigation is led by an attorney with prior financial ties to several of its institutional subjects.
LittleSis network data (entity 254763) records the following. Positions: SDNY US Attorney (current), Apollo Lead Independent Director (2021-02-18), SEC Chairman, and Sullivan & Cromwell partner. Business: counsel to Goldman Sachs and to KPMG (regarding an auditor tipped off before a regulatory inspection). Social: golf partner of Donald Trump, friend of Annette Nazareth (former SEC Commissioner). Donations: Chuck Schumer 2K Dec 2021, Mike Crapo 2K Dec 2021 (Senate Banking ranking member), 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 as a Thouron Scholar, UPenn Law JD cum laude.
identity (1)
Clayton was a Sullivan & Cromwell partner from 1993 to 2017 and co-head of the corporate practice on the Management Committee. He served as SEC Chairman from May 2017 to December 2020, joined Apollo as Lead Independent Director in February 2021 and became Non-Executive Chairman after Black resigned in March 2021, and was appointed SDNY US Attorney in April 2025 (judges confirmed August 2025). At Sullivan & Cromwell he advised Goldman on its TARP bailout, Bear Stearns on the JPMorgan fire sale, and Barclays on Lehman, worked the Alibaba IPO, and represented Reid Hoffman. His wife Gretchen Butler Clayton was a Goldman VP for 17 years and resigned on his SEC confirmation.