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

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It is easy to condemn Deutsche Bank for willful negligence, if not complicity, in facilitating Jeffrey Epstein’s sex trafficking enterprise.

Epstein was a felon and registered sex offender with a trail of outspoken victims by the time of onboarding in 2013. Indeed, the institution classified him as high risk, an admission of awareness in its own right. Thus, when the bank allegedly failed to prevent money laundering or other use of its services to facilitate Epstein’s criminal activities, there was little credible defense to be made.

It is harder to fault JPMorgan Chase for willful negligence—at least on the face of it. Epstein’s double life was ostensibly under wraps when JPMorgan onboarded him at the turn of the century.

Epstein began doing business with JPMorgan as early as 1998, according to the 2022 U.S. Virgin Islands’ (USVI) lawsuit against the bank, although a separate, class-action lawsuit brought by Jane Doe in 2022 sets the relevant timeline from 2000-13. In either case, Epstein skirted law enforcement and public scrutiny for a handful of years while a client at JPMorgan.

“Between 2000 and 2005, Epstein provided clients to JPMorgan and, in exchange, JPMorgan allowed Epstein to do as he pleased with his JPMorgan accounts. JPMorgan allowed Epstein to engage in structuring violations and other financial maneuvers required to maintain a criminal enterprise. The relationship continued without much of a question from outsiders,” alleged court documents from the Jane Doe case.

The earliest public allegation against Epstein, concerning solicitation of prostitution, surfaced in 2006. A blitz of other allegations of sexual offenses—more victims, more press reports, more lawsuits—followed in short order.

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