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Harvard will adopt new donor guidelines as a result of its review of donations from the late financier and convicted sex offender Jeffrey E. Epstein, University President Lawrence S. Bacow announced in an email to affiliates Friday afternoon.

Epstein — who died in prison in August awaiting trial on sex trafficking charges — boasted deep, longstanding ties to the University. The Miami Herald reported in November 2018 that Epstein operated a sex ring out of his Palm Beach, Fla. home and identified around 80 women who said Epstein molested or sexually abused them before 2006.

Bacow requested the review into the University’s ties to Epstein in September 2019, following the conclusion of a partial financial review. Harvard’s Office of the General Counsel — helmed by newly appointed Vice President and General Counsel Diane E. Lopez — led the review, working alongside Foley Hoag, an outside law firm.

In the intervening months, the reviewers interviewed more than 40 individuals, according to a report released Friday. They also collected and searched through more than 250,000 pages of documents — including faculty and staff emails, in accordance with email search procedures the University created in 2014.

Ultimately, the group confirmed that Epstein donated around $9.1 million between 1998 and 2008, and that the University took no gifts from Epstein following his 2008 conviction. Additionally, its investigation shed new light on his academic connections to the University, probing his status as a Visiting Fellow and his relationship to the Program for Evolutionary Dynamics. From those findings, it issued a set of recommendations — which, according to Bacow, the University will act upon “immediately.”

“The report issued today describes principled decision-making but also reveals institutional and individual shortcomings that must be addressed—not only for the sake of the University but also in recognition of the courageous individuals who sought to bring Epstein to justice,” Bacow wrote.

Epstein’s Financial Ties

The complete amount Epstein donated totaled to $9,179,000, according to the reviewers’ report. The wealthy financier was first charged in 2006, and convicted in 2008, of one count of solicitation of prostitution and one count of solicitation of prostitution with a minor under the age of 18. After allegations against Epstein resurfaced in the wake of the Herald expose, the Southern District of New York arrested him in July 2019 and charged him with trafficking dozens of minors in New York and Florida between 2002 and 2005.

Epstein’s 22 gifts to Harvard include a $736,000 donation made after his 2006 arrest but before the 2008 conviction, according to the report. He made his largest gift, totaling $6.5 million, in 2003 to establish the University’s Program for Evolutionary Dynamics, which is led by Mathematics and Biology professor Martin A. Nowak.

In a separate review, Harvard found that $200,937 in donations the University received from Epstein remain unspent. Bacow announced Friday that those funds would be divided equally between two non-profits supporting victims of human trafficking and sexual assault, My Life My Choice and Girls Educational & Mentoring Services.

Sometime between her inauguration on July 1, 2007 and November 2008, former University President Drew G. Faust decided Harvard would no longer accept gifts from Epstein, according to the report. Harvard did not accept any gifts from Epstein following his 2008 conviction.

The report also notes that former Dean of the Faculty of Arts and Sciences Micheal D. Smith “rejected” a request from several faculty members in 2013 to “reconsider the decision not to accept contributions.”

Though Epstein introduced other donors to the University after 2008, the review did not find evidence that Epstein “directed” those donations. The donors gave $7.5 million and $2 million to support the work of Nowak and Harvard Medical School Professor George Church, respectively.

Epstein had been engaged in the practice of coordinating such donations for years. In September 2019, The Crimson found that Epstein facilitated the leading donation that funded the construction of Harvard Hillel’s building in the 1990s.

Epstein’s Visiting Fellow Status

Separate from its financial findings, the report also contained an account of reviewers’ investigation into Epstein’s status as a Visiting Fellow in the Psychology Department during the 2005-2006 academic year.

The Graduate School of Arts and Sciences typically selects people with Ph.D.s or “comparable professional experience” to be Visiting Fellows, according to the report. The Fellows are not degree candidates, and they do not take courses for academic credit; instead, they audit classes while focusing on independent research.

The review found that the financier — who did not have an undergraduate degree — lacked the academic qualifications typically possessed by Visiting Fellows. But Epstein’s application included a letter of recommendation from Stephen Kosslyn, the chair of the Psychology Department at the time.

“Jeffrey's high level of intellectual acumen and breadth of knowledge is all the more remarkable given his background: He never finished his undergraduate education, and is largely self-taught,” Kosslyn wrote in the letter, according to the report. “Jeffrey has been a spectacular success in business, and it is clear why: He's not just intelligent and well-informed, he's creative, deep, extraordinarily analytic, and capable of working extremely hard.”

Kosslyn did not respond to a request for comment Friday.

The review found that Epstein did not engage with Harvard undergraduates during his time as a Visiting Fellow, though. He reapplied in February 2006 to be a Fellow for the 2006-2007 academic year, and the University readmitted him, per the report. After his September 2006 arrest, the University asked Epstein to withdraw as a Visiting Fellow, which he did.

Following his 2008 conviction, Epstein was required to register as a Level III sex offender in Florida and New York.

Yet after being released in 2009, Epstein repeatedly visited the Program for Evolutionary Dynamics’s Cambridge offices at One Brattle Square.

Documents the investigators reviewed did not show precisely how many times Epstein visited the offices, according to the report; namely, they lacked records to identify any visits he may have made between 2003 and 2009.

Though the records of Epstein’s visits after 2009 “are not precise,” the report estimates he visited the PED more than 40 times between 2010 and 2018. It counts six visits in 2018, at least one as recent as October of that year.

During those visits, Epstein met with scholars and public figures from Harvard and other institutions to hear about their work, according to the report.

“When Epstein visited PED, he typically met with leading scholars from Harvard and elsewhere in science and math and, occasionally, individuals involved in public life,” the report reads.

The investigation found that Epstein would plan the guest list at such events. The Crimson reported in 2018 that then-University President Lawrence H. Summers and former FAS Dean Henry A. Rosovsky each attended at least one event Epstein hosted at PED, as did a wide array of faculty members, including Kosslyn and Harvard Law School professor Alan M. Dershowitz.

Epstein “was routinely accompanied on these visits by young women, described as being in their 20s, who acted as his assistants,” according to the report.

PED allowed Epstein keycard and passcode access to its offices, possibly violating University policies, according to the report.

In one room which Epstein and his assistants kept keys to, Epstein brought in his own rug and hung several photographs on the wall, according to the report.

Those who worked at PED referred to the space — Office 610 — as “Jeffrey’s Office.”

“PED made Office 610 available to other visitors from time to time, and Professor Nowak informed us that, in his view, the office was only nominally Epstein’s and that it was simply a visitor’s office that was called “Jeffrey’s Office,”” the report reads. “But others who worked at PED, where office space was often scarce, generally did not view it as interchangeable with other offices, and believed it was reserved for Epstein’s use when he came.”

“Until 2017, PED maintained a Harvard telephone line in that office identified as Epstein’s. PED removed it that year as a cost-cutting measure,” the report continues.

The report goes on to state that, in an attempt to “burnish Epstein’s reputation,” Epstein’s publicist asked the PED to post links to websites for Epstein’s charitable foundations on its Harvard website.

In 2014, the publicist requested that Nowak feature Epstein in a full page on the program’s website.

Nowak approved both requests, according to the report.

“At the publicist’s request, PED added an entire page about Epstein to the website,” the report reads. “The page included his photograph, a biography, and links to Epstein’s own websites. Epstein’s page was linked to the rest of the PED website by a tab labelled “Friends” (Epstein was the only “Friend” listed on the PED website).”

The investigators found no evidence that University or FAS administrators knew about the postings, which also possibly violate University policy, according to the report. The PED removed the Epstein page after Harvard received complaints in 2014 from an advocacy group, per the report.

The Report’s Final Recommendations

The report’s extensive findings conclude with several recommendations.

The report suggests that Harvard develop clearer mechanisms for reviewing potentially controversial gifts, and that the University create procedures to ensure that Harvard’s decision to not accept such gifts are communicated and faithfully executed once the decision has been made.

It advises that, rather than devising “a complex set of rules intended to be applicable in all circumstances,” the University’s Gift Policy Committee should create a set of “triggering criteria” about donors and gifts that every faculty member, department chair, and relevant staff member should be trained to recognize.

“We believe this is necessary because our review made clear that a faculty member’s interest in his own work; a department chair’s interest in his own department; and even the pressure development staff feel to raise money rather than reject it all have the capacity to influence judgments in ways that could be detrimental to Harvard’s interests as an institution,” the reviewers wrote.

The report also urges Harvard to revise its procedures for the appointment of Visiting Fellows, requiring extra steps for disclosing potential conflicts of interest between applicants and faculty recommenders, and added layers of review for candidates who lack doctoral degrees.

Finally, the report recommends that Harvard should consider whether further actions should be taken related to the Program for Evolutionary Dynamics. It cites an incident in which Nowak falsely informed a grant-making foundation that matching funds for a PED grant came from a foundation run by Epstein, suggesting that Harvard report the incident to FAS’s Faculty Affairs Office.

FAS Dean Claudine Gay announced in an email Friday afternoon that the FAS has placed Nowak on paid administrative leave as a result of the Epstein review’s findings. Nowak did not respond to a request for comment.

The University’s top leadership will implement the recommendations as soon as possible, according to Bacow’s Friday email. Provost Alan M. Garber ’76 will lead the effort to expand procedures of reviewing potential gifts, while Vice President of Alumni Affairs and Development Brian K. Lee will work to ensure the procedures in the report relate to alumni affairs and development staff.

—Staff writer Michelle G. Kurilla can be reached at michelle.kurilla@thecrimson.com. Follow her on Twitter @MichelleKurilla.