USVI Financial Services Legislation: A 284-Page Bill Drafted by Epstein's Private Attorney for the Governor
Between August and December 2016, William Blum — a partner at Solomon Blum Heymann LLP, a New York firm at 40 Wall Street — drafted a 284-page bill titled the "Virgin Islands Financial Services Improvement and Corporate Modernization Act" for submission to the USVI Legislature under Governor Kenneth Mapp's name. The bill was designed to position the U.S. Virgin Islands as an onshore alternative to offshore financial centers such as the Cayman Islands, BVI, Bermuda, and Channel Islands by creatin
USVI Financial Services Legislation: A 284-Page Bill Drafted by Epstein's Private Attorney for the Governor
Executive Summary
Between August and December 2016, William Blum — a partner at Solomon Blum Heymann LLP, a New York firm at 40 Wall Street — drafted a 284-page bill titled the "Virgin Islands Financial Services Improvement and Corporate Modernization Act" for submission to the USVI Legislature under Governor Kenneth Mapp's name. The bill was designed to position the U.S. Virgin Islands as an onshore alternative to offshore financial centers such as the Cayman Islands, BVI, Bermuda, and Channel Islands by creating statutory trust vehicles with automatic tax exemptions and asset protection features modeled on South Dakota, Alaska, Nevada, and New Hampshire law.
Blum did not send the drafts to the Governor. He sent them to Jeffrey Epstein — a registered sex offender — who forwarded them to Governor Mapp. The email correspondence, preserved across multiple EFTA documents, shows Epstein acting as the sole intermediary between his private attorney and the sitting Governor throughout the four-month drafting process.
This investigation was separately reported — in a different context — by media outlets including NBC News, Law & Crime, and Fox Business, which documented Epstein's attorneys drafting sex offender monitoring legislation in 2011-2012. The financial services legislation described here is an entirely different bill, drafted four years later, by a different attorney, for a different governor, and has not been previously reported.
The Attorney
William Blum's professional biography, published on his firm's website (Solomon Blum Heymann LLP), states that he served as counsel to the USVI Governor from 1981 to 1984, during which time he "authored the legislation establishing the USVI's foreign sales corporation and exempt company laws" and "drafted initial regulations" for the Virgin Islands Economic Development Commission (EDC) tax exemption program. These are the foundational statutes that enabled entities like Epstein's Financial Trust Company and Southern Trust Company to claim 90% income tax exemptions in the USVI.
Blum is simultaneously listed as Of Counsel at Kellerhals Ferguson Kroblin PLLC, the St. Thomas firm that served as Epstein's primary USVI legal team and subsequently administered the Epstein estate. His Kellerhals bio describes him as "the foremost expert on the utilization of the U.S. Virgin Islands as a tax haven for non-U.S. persons."
The Bill
The bill's contents are known only from the drafting correspondence. The 284-page document itself was transmitted as an email attachment and was not extracted into the EFTA text corpus. What follows is reconstructed from the cover emails between Blum, Epstein, and — in one instance — Governor Mapp.
Purpose
On August 23, 2016, Blum wrote to Epstein (copying Erika Kellerhals of Kellerhals Ferguson Kroblin):
"Attached for your review and comment is our memo constituting the first part of our analysis regarding the possibility of establishing the VI as a jurisdiction where large US corporations could move their asset holding subsidiaries presently located in other foreign jurisdictions such as Ireland or other offshore locations such as Bermuda, BVI, Cayman, Channel Islands, etc. The focus of the memo is on IRC sections 367 and 1248." (EFTA02454259)
In the same email, Blum described the statutory trust component:
"I am cleaning up the draft statutory trust legislation prepared for the Governor by Peter Hiebert. Peter's draft of this legislation was lifted directly from Delaware (which is good). The initial changes I am making relate to putting it in proper VI legislative form, as well as making substantive changes to adopt provisions of the law of other jurisdictions (or new provisions) that are more favorable than those of Delaware. Asset protection is the main focus there and the jurisdictions we are primarily looking at in this regard are South Dakota, Alaska, New Hampshire, Nevada, and Cayman Islands."
Blum also described the tax structure:
"We are trying to work out a method by which the tax exemption for these entities will be automatic for some purposes/owner, i.e., no approval of an agency such as the EDC required; rather the exemption would be statutory if requirements are met like with USVI exempt companies."
Epstein replied: "when will you have the draft. we need a fully examined bill ready by third week of sept?"
Epstein's Trust Provisions
On September 15, 2016, Epstein sent Blum an eight-point list of trust features to incorporate into the bill:
(Item 3 is missing from the OCR; the numbering jumps from 2 to 4 in the source document.)
Tax Provisions
In his September 20, 2016 response to Epstein's list, Blum wrote:
"I have also drafted a provision to eliminate the 'Obama care tax' (formally known as the Net Investment Income Tax) with respect to USVI source interest and dividends in the future as well as some provisions to assist in enforcement of the tax with respect to past years (the tax started in 2013). Apparently, a lot of taxpayers have not been paying it arguing that it is not mirrored." (EFTA02042877)
Blum added:
"But this also brings up again the issue of an equivalent of PR Act 22 to eliminate all taxes on VI source capital gains (at least on personal property) and other passive income to the extent allowed by the IRC. In PR this only applies to newcomers. We need to talk about this."
Puerto Rico's Act 22 (now Act 60) provides 0% capital gains tax to new residents of the island. Blum was considering whether the USVI should adopt an equivalent provision.
The Apple/Ireland Model
The bill's subject line in the email thread was "Virgin Islands Financial Services Improvement and Corporate Modernization Act." On September 13, 2016, when Epstein asked whether the bill addressed "inbound and outbound to the u.s.? 367 etc, or exit tax?", Blum replied:
"Not yet. I am waiting on input from Peter and Barry on both of those issues, especially the exit tax. We need to understand, fairly precisely, how Apple/Microsoft, et al. are being taxed in Ireland in order to try to replicate that, if we can, in the VI." (EFTA01782906)
The attorneys involved in this analysis were Peter Hiebert (who drafted the initial statutory trust provisions based on Delaware law) and Barry Hart (who worked on exit tax and Irish corporate tax replication). Blum noted they "have promised some input from contacts who may know those types of details."
The Intermediary Pattern
The Drafting Process (August–October 2016)
Throughout the four-month drafting period, Blum sent all drafts to Epstein. The correspondence shows Blum explicitly controlling when the Governor would see the legislation.
September 8, 2016: Epstein emails Blum and Kellerhals with a one-word message: "draft?" Blum replies:"Preliminary by end of day tomorrow. Which I will send to you and Peter Hiebert so you can start to read it, but please don't send it to anyone, including the Governor." (EFTA01782654)
Blum continued: "I expect a fully proofread and more perfected version by middle of next week and that one could be circulated more widely for review in advance of a 'final' version, to incorporate changes and comments, which presumably would be ready for the Governor before the end of the month."
September 13, 2016: Blum sends Epstein the "First Draft," stating: "I am also going to share this now with Peter Hiebert and Barry Hart as well as with others in our firm who have worked on the bill." He adds: "I expect that Peter and Barry, as well as other attorneys in both firms will have some further suggestions which we will need to incorporate in future drafts before we send it on to the Governor." (EFTA01782906) October 8, 2016: Blum sends version 7 — 284 pages — writing:"This is the latest version. Main differences from prior drafts is a revised title 15, section 1423 re tax exemptions for statutory trusts (pp 45-36) — which Barry and Peter have essentially signed off on -- as well as inclusion of uniform principal and income act (starts at p. 100) which is standard. Other changes were just clean up. Except for repatriation, we are almost done I think." (EFTA02448555)
"I am reserving space at the end (p. 284) to add the repatriation stuff — once we decide what we are doing on that."
The Transmittal to the Governor
October 18, 2016: Blum sends Epstein a proposed transmittal letter — written as if from the Governor to the Legislature:"Attached is the proposed transmittal letter to the Legislature from the Governor. I tried to draft it as a mostly 'political' document, as opposed to the Explanation section of the bill itself which is more technical and 'explanatory.' Please give me any comments." (EFTA01738723)
"Please note that I have not yet included the repatriation provisions in the letter because (1) I have not drafted them yet, and (2) I am unsure of how you think the Governor will want to handle that issue politically."
This sentence is notable: Blum asks Epstein — not the Governor — how the Governor will want to handle a political issue.
Blum also described his concept for the repatriation provisions: "my thought about how to draft the repatriation provisions is to establish a special type of statutory trust that requires a very large capital investment, the 25 employees we talked about, and the requirement that the trust and its assets remain in the USVI for a minimum period of time, etc."
October 23, 2016: Epstein forwards Blum's "Legislation" email to Governor Kenneth E. Mapp, adding: "see you tues?" October 24, 2016: Governor Mapp replies to Epstein: "Got it, thanks."The Follow-Up (November–December 2016)
November 22, 2016: Blum writes to Epstein: "Do you know what the status of the legislation is with the Governor?" December 7, 2016: Blum follows up again: "Hi, Jeff. Can you give me any update on this?"Epstein replies: "ill see the governor tomorw"
Blum responds: "OK. Please let me know his plans/timing for this. I can be available, of course, for questions, etc."
The email subject line throughout this thread is "Financial Services/trust/repatriation legislation."
The Epstein-Mapp Relationship
The legislation was not drafted in a vacuum. The broader email corpus documents an established relationship between Epstein and Governor Mapp, facilitated by Cecile de Jongh — the wife of Mapp's predecessor, Governor John de Jongh Jr. (2007–2015) — who simultaneously worked as an "office manager" at Epstein's Financial Trust Company in St. Thomas.
August 4, 2014: While Mapp was still a candidate for governor, Cecile wrote to Epstein's assistant Lesley Groff: "I would like to set up a FTF meeting for JE with Kenn Mapp (candidate for governor of the VI). I think the meeting should take place some time at the end of August but I need to make sure the JE is in the VI at that time." (EFTA01852880) March 10, 2015: After Mapp took office in January 2015, Cecile sent Epstein a detailed intelligence briefing titled "Back Brief" — 13 bullet points on the new Governor's agenda, including appointments, federal negotiations, and fiscal condition:"Below are some back brief bullet points on some issues in preparation for your meeting with Mapp on Thursday. I'm not sure what the meeting is about but I wanted to give you a sense of what is happening in the community and issues that he has raised." (EFTA01746665)
Among the items: the U.S. Treasury reducing the EDC residency requirement to 153 days, a White House meeting about using the HOVENSA facility as a Guantanamo replacement, and the USVI Commissioner of Finance testifying that "the GOVI only has two weeks of cash on hand."
Blum also maintained a direct relationship with Governor Mapp. In his August 23, 2016 email to Epstein, Blum noted: "I spoke with Governor Mapp about ten days ago and also I might see him when I am on island early next week" (EFTA02454259).
What Remains Unknown
Several critical questions cannot be answered from the available corpus:
Drafting Timeline
| Date | Event | Source |
| ------ | ------- | -------- |
| 1981–1984 | Blum serves as counsel to USVI Governor; authors exempt company/EDC legislation | Blum firm bios |
| 08/04/2014 | Cecile arranges Epstein meeting with candidate Mapp | EFTA01852880 |
| 01/05/2015 | Mapp inaugurated as Governor | Public record |
| 03/10/2015 | Cecile sends Epstein "Back Brief" on Mapp's agenda | EFTA01746665 |
| ~08/13/2016 | Blum speaks with Governor Mapp | EFTA02454259 |
| 08/23/2016 | Blum sends Epstein memo on establishing USVI as financial jurisdiction | EFTA02454259 |
| 08/24/2016 | Epstein: "we need a fully examined bill ready by third week of sept" | EFTA02454259 |
| 09/08/2016 | Blum: "please don't send it to anyone, including the Governor" | EFTA01782654 |
| 09/13/2016 | Blum sends "First Draft"; discusses Apple/Ireland tax replication | EFTA01782906 |
| 09/15/2016 | Epstein sends 8-point trust provisions wishlist | EFTA02042877 |
| 09/20/2016 | Blum drafts Net Investment Income Tax elimination | EFTA02042877 |
| 10/08/2016 | Blum sends version 7 — 284 pages | EFTA02448555 |
| 10/18/2016 | Blum drafts transmittal letter from Governor to Legislature | EFTA01738723 |
| 10/23/2016 | Epstein forwards bill to Governor Mapp: "see you tues?" | EFTA01738723 |
| 10/24/2016 | Governor Mapp replies: "Got it, thanks" | EFTA01738723 |
| 11/22/2016 | Blum asks Epstein: "what the status of the legislation is with the Governor?" | EFTA01787145 |
| 12/07/2016 | Epstein: "ill see the governor tomorw" | EFTA01787145 |
Methodological Notes
- All EFTA citations were verified against the
full_text_corpus.dbdatabase. Dataset assignments were confirmed via SQL query.
- The 284-page bill itself was transmitted as an email attachment (likely PDF) and was not extracted into the EFTA text corpus. Only the cover emails are available. All descriptions of the bill's contents are derived from what the drafters wrote about it in correspondence.
- Quoted passages from the corpus are drawn from OCR-processed text. Where OCR artifacts are obvious (e.g.,
=characters from quoted-printable encoding), corrections are made silently when the intended text is unambiguous from context. Original OCR text is preserved in the database and can be verified atepstein-data.com/full_text_corpus/pages?efta_number=EFTA....
- William Blum's professional biography is drawn from publicly available firm websites: Solomon Blum Heymann LLP and Kellerhals Ferguson Kroblin PLLC.
- Cecile de Jongh's role at Epstein's Financial Trust Company and the $200,000 wire from Southern Trust Company are documented in a Deutsche Bank presentation to SDNY prosecutors (EFTA01681865 — OCR text, page 36, "Exhibit P: Notable Payments to High Profile Individuals"). This document has been removed from justice.gov.
- The sex offender monitoring legislation drafted by Epstein's associates in 2011-2012 — reported by NBC News, Law & Crime, and Fox Business — is a different bill drafted by different individuals for a different governor. This report concerns financial services legislation drafted in 2016.
- No evidence was found that the bill was submitted to the USVI Legislature or enacted into law.
This analysis relies on automated corpus search and Claude Code running Opus 4.6, which can make mistakes. All citations should be verified against the source documents.