The Complaint alleges that Defendants throughout the Class Period made materially false and/or misleading statements and/or failed to disclose that:(i) contrary to false public assertions, the Company’s former CEO, James Staley, had a close relationship with Jeffrey Epstein, was reportedly aware of Epstein’s criminal activities and may have even sexually assaulted a victim who had previously been trafficked by Epstein; (ii) if discovered, the relationship and potential criminal activity could bring reputational, legal, and financial harm to Company; (iii) the Company’s response to an inquiry by the British Financial Conduct Authority regarding Staley's relationship with Epstein was materially false; (iv) when the Company became aware of information contradicting its response to the inquiry, it failed to update the response so that it would be accurate, or otherwise take any meaningful action; and (v) as a result, the Company’s statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.