With sordid tales of Jeffrey Epstein once again in the media—haunting former President Donald Trump and other alleged associates implicated on the (now branded “fictitious”) Epstein list—new attention is being directed at the financial institutions that served him: JPMorgan Chase and Deutsche Bank.

This week, The New York Times Magazine published an in-depth investigation revealing how high-level executives at JPMorgan Chase enabled Epstein’s criminal enterprise for years, and the vested interests they had in turning a blind eye.

The NYT Magazine’s report echoed many of the insights contained in Compliance Week’s March 2024 case study, “The Banks Behind the Epstein Enterprise,” which examined how both JPMorgan Chase and Deutsche Bank supported Epstein’s sex trafficking operation. The case study also examined failures in compliance, ethics, and due diligence at both institutions.

Why does the story of Epstein’s enablers at two major banks hit harder today than it did 18 months ago?

For one, powerful individuals tied to Epstein—and the media structures that shield them—are actively working to rewrite the narrative. The so-called “Epstein list” is being dismissed as a hoax by those who may stand to lose the most from its legitimacy. In response, many of Epstein’s survivors have come forward to publish their own records, refusing to be silenced or gaslit. 

Virginia Giuffre, who was the first of Epstein’s survivors to go public in 2015, died by suicide in April. 

Meanwhile, Ghislaine Maxwell—Epstein’s long-time associate and convicted accomplice—was recently moved to a cushier prison to serve out the remainder of her 20-year sentence, where she reportedly interacts with the likes of disgraced Theranos founder Elizabeth Holmes. In a chilling political twist, Donald Trump hasn’t ruled out pardoning Maxwell for her alleged crimes. “I’m allowed to do it,” Trump said in August, “but nobody’s asked me to do it.”

These maneuvers demand truth-telling. That’s why it’s encouraging to see The New York Times Magazine shine a spotlight on JPMorgan Chase. And it’s why Compliance Week’s case study remains as vital today as when it was first published.

Unlike traditional investigative journalism, Compliance Week’s analysis offers more than an exposé—it’s a blueprint for change. For compliance professionals in financial services, the report identifies specific behavioral and financial red flags linked to human trafficking and money laundering, including:

  • Unusual withdrawal patterns;

  • Third-party transfers from multiple accounts; 

  • Clusters of high-risk nationalities opening accounts; 

  • Women receiving funds from Epstein’s accounts while listing his New York properties as their residence.

These weren’t subtle indicators. The red flags were glaring and frequent.

The case study moved beyond individual accountability to spotlight systemic failures. With expert insights from leading figures in anti-money laundering (AML) and financial compliance—including a world-renowned money laundering expert and a former Superintendent of the New York Department of Financial Services—it outlined what effective ethics and compliance programs should include, such as:

  • Transaction monitoring at the relationship level, not just the account level;

  • Perpetual KYC (Know Your Customer) practices;

  • Better integration between KYC and Customer Due Diligence (CDD); 

  • Deployment of advanced AI tools like entity resolution, natural language processing, and large language models. 

While corporate governance failures and toxic banking culture are nothing new, the last eighteen months have shown just how urgent it is for internal whistleblowers and compliance professionals to speak out.

Compliance Week’s ”The Banks Behind the Epstein Enterprise” case study exposed how compliance teams at both banks raised concerns, flagged risks, and formally objected to Epstein’s continued relationship with the institutions. Yet he was retained—because of his wealth, his social connections, and his potential to attract other lucrative clients.

Toxic incentives outweighed ethical imperatives.

In the end, the renewed spotlight on Epstein’s enablers—particularly in the financial world—is not merely a chance to revisit the past. It’s a call to confront the ongoing systems of power, profit, and silence that allowed his crimes to flourish.

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