The United States’s progress on implementing the beneficial ownership information reporting requirements contained within the Corporate Transparency Act earned it praise from the intergovernmental Financial Action Task Force.
AML
FDIC proposes strengthening, modernizing bank merger reviews
The Federal Deposit Insurance Corporation proposed to strengthen its approach to evaluating bank mergers under the Bank Merger Act, particularly how it would address factors like competition, financial resources, the convenience and needs of communities, financial stability, and money laundering.
Chapter 4: Investigations into misconduct: What banks can do
Both JPMorgan Chase and Deutsche Bank retained their respective Jeffrey Epstein relationships for too long. Yet, there is a case to be made for why exiting a high-risk relationship too soon can become an inverse form of recklessness.
Chapter 3: Egregious failures: Customer due diligence and transaction monitoring
Why did JPMorgan Chase retain Jeffrey Epstein for more than a dozen years? How did the relationship persist despite glaring red flags? The “why” is straightforward; the “how” is more complicated.
Chapter 2: KYC shortfalls: JPMorgan and Deutsche Bank’s onboarding of Epstein
Jeffrey Epstein’s designation as a high-risk client should have subjected him to enhanced due diligence that never appeared to occur, most notably at Deutsche Bank. Instead, Epstein was allowed to continue his misconduct despite numerous red flags.
Chapter 1: Compliance v. complicity: The ‘underbelly’ of bank culture
Why were decisions made the way they were at the banks that serviced Jeffrey Epstein? Evidence points to a cultural tension: a tug-of-war between the allure of profit and the drag of compliance, with the former having all the pulling power.
Case study: ‘The Banks Behind the Epstein Enterprise’
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.
FCA warns CEOs over firm AML failings
The U.K. Financial Conduct Authority warned the chief executive officers of approximately 1,000 financial institutions it supervises regarding common failures in anti-money laundering procedures it observed during recent assessments.
Judge’s ruling calls FinCEN beneficial ownership registry into question
A federal court judge in Alabama ruled the Corporate Transparency Act was beyond Congress’s power, potentially throwing the effectiveness of the Financial Crimes Enforcement Network beneficial ownership information registry into doubt.
Metropolitan Commercial Bank adds risk chief, AML officer
Metropolitan Commercial Bank announced the appointments of a chief risk officer and Bank Secrecy Act/anti-money laundering officer to bolster its reporting lines following a $30 million enforcement action from federal and state authorities last year.


