The Office of the Comptroller of the Currency cited three banks for unsafe and unsound business practices that mirror issues similar to what spurred last year’s banking crisis.
AML
FinCEN warns of fake U.S. passport cards used to commit fraud
The Financial Crimes Enforcement Network is warning financial institutions of counterfeit U.S. passport cards used to commit fraud and identity theft.
Ex-OneCoin compliance head jailed 4 years for fraud role
The former head of legal and compliance at OneCoin was sentenced to four years in prison after pleading guilty to fraud charges regarding her role in a cryptocurrency marketing scheme.
U.S. BOI efforts earn it upgraded rating from FATF
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.
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.


