Narrative 16: The Accountant
Richard Kahn's CPA practice, HBRK Associates, routed 18,833 emails across the Epstein financial network. It touched every shell. It connected every person. It appears on more documents than any entity except the core hubs. And it was an accounting firm.
11,153 Files
Richard Kahn shows up on 11,153 documents in the EFTA corpus. That's more than Southern Trust (883), Southern Financial (628), Financial Trust Company (1,014), and Gratitude America (209) combined.
7,103 of those carry the attribution "Richard Kahn / HBRK Associates Inc." Most of Kahn's footprint ties directly to his accounting practice, not personal capacity.
HBRK Associates is not a bank. Not a law firm. Not a trust company. It's a CPA practice — and it appears on more documents than any financial entity in the Epstein network.
The Email Hub
HBRK Associates' document type breakdown:
97.8% of HBRK's footprint is email. This firm wasn't preparing tax returns. It was the network's communications backbone. Every instruction, every transaction coordination, every operational decision — routed through or copied to HBRK.
The 11 flight log co-occurrences mean HBRK appeared in contexts involving aviation — the same flight records that document travel to and from St. Thomas and other Epstein locations.
Every Shell, Every Document Type
Nothing else in the network has HBRK's reach. My co-occurrence analysis shows it touching every major shell, across every document type:
Email Co-occurrence (Primary Channel)
| Shell Entity | Shared Email Files |
| ------------- | ------------------- |
| Nautilus, Inc. | (via document) |
Cross-Channel Presence
| Shell Entity | Document | Fax | Court Filing | Financial |
| ------------- | ---------- | ----- | ------------- | ----------- |
| FINANCIAL TRUST / SOUTHERN TRUST | 3 | — | — | — |
| Financial Trust Company | — | 4 | 3 | — |
HBRK doesn't just show up in emails. It co-occurs with shells across court filings, faxes, financial docs, and general documents.
Combined totals: Southern Trust/Financial (167 shared files), Butterfly Trust (27), Haze Trust (26), Jeepers (23), Gratitude America (22), Financial Trust Company (17), Epstein & Co (9), Nautilus (7).
This is not a CPA practice that prepared annual tax returns for a client. This is a CPA practice that was embedded in the daily operational communications of a 14-entity, multi-bank financial network with $2.146 billion in total extracted financial activity.
The Inner Circle
The persons who appear most frequently on HBRK-associated documents constitute the operational core of the Epstein network:
| Person | Shared Files with HBRK |
| -------- | ---------------------- |
| Jeffrey E. [OCR variants] | 3,533 |
The names are significant:
Lesley Groff (1,280 files) — Epstein's long-time personal assistant and scheduler. She was named in multiple victim lawsuits and described as a gatekeeper for Epstein's appointments. Her presence on 1,280 HBRK files means the accounting firm was in direct, frequent communication with Epstein's operational staff.
Emad Hanna (894 files) — Epstein employee involved in property and financial management.
Daphne Wallace (881 files) — Epstein's property manager for the New York residence and other locations.
Bella Klein (819 files) — Epstein assistant referenced in multiple depositions.
Karyna Shuliak (587 files) — Epstein's girlfriend at the time of his death. Her appearance on 587 HBRK files — more than many shell entities' total file counts — means the accounting firm's communications included Epstein's personal relationship.
This is not a client-accountant relationship with normal boundaries. The CPA practice was in the operational loop with Epstein's household staff, personal assistants, property managers, and girlfriend.
The Professional Standards Question
The American Institute of Certified Public Accountants (AICPA) Code of Professional Conduct establishes standards for CPA practices:
ET § 1.400.001 — Acts Discreditable: A member shall not commit an act discreditable to the profession. Knowingly facilitating financial structures designed to evade reporting requirements would constitute a discreditable act.
ET § 1.300.001 — Accounting Principles: A member shall not knowingly misrepresent facts or subordinate their judgment to the client.
Independence Standards: While HBRK was not performing attest services (audits), the level of operational integration documented here — 18,833 emails, daily coordination with staff, presence on flight logs — raises the question of whether the firm maintained the professional independence and objectivity that CPA practices are expected to exhibit.
A CPA practice that prepares tax returns for a client receives financial records, prepares returns, and corresponds periodically. A CPA practice that routes 18,833 emails across a 14-entity shell network, co-occurs on documents with the client's household staff and girlfriend, and appears on flight logs is performing a different function.
The EFTA documents don't tell us what HBRK knew about the network's purpose. They tell us the firm was at the center of it.
The Money Was Modest
The financial documents where HBRK appears show relatively modest dollar amounts:
Top money values: $25,000 (15 mentions), $100,000 (11), $2,000,000 (10), $5,000,000 (9), $2,500,000 (9), $10,000 (9), $3,000 (12).
The recurring references to invoice numbers (826119 Invoice # on 69 mentions) suggest routine accounting billings. HBRK's own fees were likely small — the standard CPA fee structure for tax preparation and bookkeeping services.
This is the point: HBRK Associates was not a major financial beneficiary of the network. The money flowing through the shells — the $60.5 million from Leon Black, the $25 million from Rothschild, the $244 million through Southern Trust — dwarfs whatever HBRK earned in professional fees. The firm's significance is not in how much money it received. It's in how much money it coordinated.
An accounting firm earning modest fees but routing 18,833 emails across a network with $2.146 billion in total financial activity. That is the disproportion that makes HBRK Associates the most structurally important entity that nobody has examined.
Methodology: Entity co-occurrence analysis of HBRK-flagged documents against shell entity names (by document type), person names, and money values. Document type classification from automated pipeline. Person co-occurrence at file level (distinct file_id). All amounts are unverified automated extractions. See
Methodology.
Source data: [Master Wire Ledger](../data/master_wire_ledger_phase5i.json) · <a href="https://docs.google.com/spreadsheets/d/11lw0QjMZ-rYIjWesv5VG1YKts57ahPEm/edit?usp=sharing&ouid=103970896670138914877&rtpof=true&sd=true" target="_blank">Forensic Workbook</a> · <a href="https://randallscott25-star.github.io/epstein-forensic-finance/visualizations/shell_network.html" target="_blank">Interactive Network</a>
Related narratives: N8: Entity Co-Occurrence ·
N11: The Shell Map ·
N14: Leon Black ·
N15: Gratitude America
All findings are (Unverified) automated extractions from DOJ EFTA documents released under the Epstein Files Transparency Act. Entity mention does not imply wrongdoing. This analysis identifies patterns for further investigation — it does not make legal conclusions.
For the girls.
Source Documents & Exhibits
Primary Source
Corpus-wide analysis of HBRK Associates / Richard Kahn entity co-occurrence across all document types.
Key EFTA Corpus Statistics
- HBRK Associates / Richard Kahn: 11,153 files (7,103 as "Richard Kahn/HBRK Associates Inc.")
- Document type distribution: Email (18,833), Financial (133), Document (108), Letter (91), Court Filing (20), Fax (15), Flight Log (11), Subpoena (7), Phone Record (2) — 97.8% email
- Method: Entity co-occurrence analysis for "HBRK" across all document types and shell entities
Shell Co-Occurrence by Document Type
| Shell Entity | Email | Document | Fax | Court Filing | Financial |
| ------------- | ------- | ---------- | ----- | ------------- | ----------- |
| Gratitude America | 8+5+3+3 | — | — | — | — |
| Financial Trust Company | 7 | — | — | — | — |
Method: Shell entity × HBRK co-occurrence partitioned by doc_type.
Inner Circle (by file co-occurrence with HBRK)
Richard Kahn (11,153), Jeffrey Epstein (4,510), JEE variants (7,300 combined), Rich Kahn variants (2,122), Lesley Groff (1,280), Emad Hanna (894), Daphne Wallace (881), Bella Klein (819), Karyna Shuliak (587).
External Corroboration
- "HBRK stands for Harry Beller Richard Kahn" — 2025 Bank of America and BNY Mellon class action lawsuits, SDNY
- Senate Finance Committee letter (Wyden et al., December 2025): Kahn had signatory authority over Epstein accounts at JPMC "and other financial institutions"
- JPMorgan SARs: "Kahn was a primary actor in movement of Epstein's funds" and "potentially assisted in facilitating the sex trafficking ring" (2023 JPMC internal KYC profile)
- Bella Klein confirmed as Kahn's assistant who communicated with trafficking victims about wire transfers (BofA class action)
- DOJ/FBI never questioned Kahn or Indyke in connection with any criminal investigation (Senate Finance Committee, December 2025)
- Bank of America lawsuit: Kahn "devised schemes to entrap" trafficking victims and "serviced the taxes of numerous Epstein victims"
📄 EFTA Source Documents
Click any document ID to open the DOJ PDF in a new tab. Click a Dataset number to browse neighboring files.
| Document | Source | Description |
| ---------- | -------- | ------------- |
| Full EFTA Corpus | DS1–12 | HBRK Associates / Richard Kahn: 11,153 files (18,833 emails) |
| Full EFTA Corpus | DS1–12 | Shell entity co-occurrence: Southern Financial (89), Southern Trust (96), Haze Trust (22) |
| <a href="https://www.justice.gov/epstein/doj-disclosures/data-set-8-files" target="_blank">Dataset 8</a> | DS8 | Browse Dataset 8 |
| <a href="https://www.justice.gov/epstein/doj-disclosures/data-set-9-files" target="_blank">Dataset 9</a> | DS9 | Browse Dataset 9 — primary email archive location |
Note: Kahn's document footprint spans all 12 datasets. Email volume (18,833) exceeds all other entity types combined.
All 12 DOJ Datasets: <a href="https://www.justice.gov/epstein/doj-disclosures/data-set-1-files" target="_blank">1</a>, <a href="https://www.justice.gov/epstein/doj-disclosures/data-set-2-files" target="_blank">2</a>, <a href="https://www.justice.gov/epstein/doj-disclosures/data-set-3-files" target="_blank">3</a>, <a href="https://www.justice.gov/epstein/doj-disclosures/data-set-4-files" target="_blank">4</a>, <a href="https://www.justice.gov/epstein/doj-disclosures/data-set-5-files" target="_blank">5</a>, <a href="https://www.justice.gov/epstein/doj-disclosures/data-set-6-files" target="_blank">6</a>, <a href="https://www.justice.gov/epstein/doj-disclosures/data-set-7-files" target="_blank">7</a>, <a href="https://www.justice.gov/epstein/doj-disclosures/data-set-8-files" target="_blank">8</a>, <a href="https://www.justice.gov/epstein/doj-disclosures/data-set-9-files" target="_blank">9</a>, <a href="https://www.justice.gov/epstein/doj-disclosures/data-set-10-files" target="_blank">10</a>, <a href="https://www.justice.gov/epstein/doj-disclosures/data-set-11-files" target="_blank">11</a>, <a href="https://www.justice.gov/epstein/doj-disclosures/data-set-12-files" target="_blank">12</a>
📊 Verify in Forensic Workbook
| Exhibit / Analysis | View in Workbook |
| Shell Network — HBRK × shell co-occurrence | <a href="https://docs.google.com/spreadsheets/d/11lw0QjMZ-rYIjWesv5VG1YKts57ahPEm/edit?gid=1040516313#gid=1040516313" target="_blank">📊 Open Tab</a> |
| Entity P&L — Richard Kahn / HBRK | <a href="https://docs.google.com/spreadsheets/d/11lw0QjMZ-rYIjWesv5VG1YKts57ahPEm/edit?gid=1497389416#gid=1497389416" target="_blank">📊 Open Tab</a> |
| Shell Trust Hierarchy — HBRK position | <a href="https://docs.google.com/spreadsheets/d/11lw0QjMZ-rYIjWesv5VG1YKts57ahPEm/edit?gid=1943952132#gid=1943952132" target="_blank">📊 Open Tab</a> |
| Executive Summary | <a href="https://docs.google.com/spreadsheets/d/11lw0QjMZ-rYIjWesv5VG1YKts57ahPEm/edit?gid=1804001356#gid=1804001356" target="_blank">📊 Open Tab</a> |
| Methodology | <a href="https://docs.google.com/spreadsheets/d/11lw0QjMZ-rYIjWesv5VG1YKts57ahPEm/edit?gid=1840632994#gid=1840632994" target="_blank">📊 Open Tab</a> |
How to Verify
EFTA document IDs from public DOJ release at <a href="https://efts.gov" target="_blank">efts.gov</a>. Full methodology in METHODOLOGY.md.