This Compliance Week case study offers a deep dive into the anti-money laundering compliance failures-and alleged complicity-of JPMorgan Chase and Deutsche Bank, the two banks that enabled the Jeffrey Epstein enterprise to flourish for decades.

Compliance Week’s latest case study, “The Banks Behind the Epstein Enterprise,” tells an old story through a new lens. The report offers a deep dive into the anti-money laundering (AML) compliance failures—and alleged complicity—of JPMorgan Chase and Deutsche Bank, the two banks that enabled the Epstein enterprise to flourish for decades.

It features exclusive interviews with a former New York State Department of Financial Services regulator, a world-renowned money laundering expert, AML compliance officers, expert financial crime fighters, and more.

This was written in March 2024, but seems pretty relevant given JP Morgan’s refusal to hand over records of Epstein’s transactions to the Senate Finance committee without a subpoena.

This is a long article broken down into an introduction and 4 chapters:

Chapter 1: Compliance v. complicity: The ‘underbelly’ of bank culture

Chapter 2: KYC shortfalls: JPMorgan and Deutsche Bank’s onboarding of Epstein

Chapter 3: Egregious failures: Customer due diligence and transaction monitoring

Chapter 4: Investigations into misconduct: What banks can do

I also recently posted 2 shorter related articles in another community. One is an article written last week about the lack of any changes to bank policy and oversight, despite the role JP Morgan played allowing Epstein’s financial transactions to continue until 2013. The other is a 2017 article about Epstein’s self reported interest in cryptocurrency.