On March 6, 2008, this Office announced the filing of criminal charges related to an international prostitution ring known as the Emperors Club VIP. The investigation which led to those charges began when this Office learned of payments made in a questionable manner by former Governor SPITZER to a bank account in the name ‘QAT Consulting.’ After the investigation by the Federal Bureau of Investigation and the United States Internal Revenue Service — Criminal Investigation Division, the Office determined that the QAT Consulting account and a similar account at another financial institution had been used to launder more than $1 million worth of criminal proceeds derived from the Emperors Club VIP’s prostitution business.

ELIOT SPITZER has acknowledged to this Office that he was a client of, and made payments to, the Emperors Club VIP. Our investigation has shown that on multiple occasions, Mr. SPITZER arranged for women to travel from one state to another state to engage in prostitution. After a thorough investigation, this Office has uncovered no evidence of misuse of public or campaign funds. In addition, we have determined that there is insufficient evidence to bring charges against Mr. SPITZER for any offense relating to the withdrawal of funds for, and his payments to, the Emperors Club VIP.

In light of the policy of the Department of Justice with respect to prostitution offenses and the longstanding practice of this Office, as well as Mr. SPITZER’s acceptance of responsibility for his conduct, we have concluded that the public interest would not be further advanced by filing criminal charges in this matter.