In 2020, Bank of America flagged a series of high-value transactions involving deceased financier and convicted sex offender Jeffrey Epstein and billionaire Leon Black. These payments, totaling $170 million, were flagged in two suspicious activity reports (SARs) submitted to federal regulators—a full year after Epstein’s death in August 2019.
The delayed reporting has raised significant questions about whether the bank violated federal money laundering laws. Congressional investigators are now scrutinizing the timing and handling of these transactions, which had gone unexamined for years.
Suspicious activity reports are vital tools used by financial institutions to alert authorities to potential crimes like money laundering, fraud, or terrorist financing. According to a congressional memorandum prepared under the direction of Senate Finance Committee Chairman Ron Wyden, Bank of America submitted the SARs in February 2020 and October 2020.
However, the transactions in question occurred years earlier, during Epstein’s active financial dealings. The bank reportedly processed the payments without investigating their purpose or seeking further information.
This lack of oversight has led investigators to question why it took Bank of America so long to act and whether their delay constitutes a breach of federal regulations.
The payments involved in the SARs were made by billionaire Leon Black, a former Apollo Global Management CEO, to Epstein. Black has acknowledged that he paid Epstein millions of dollars for financial advice, including estate planning services. However, Epstein’s reputation as a convicted sex offender and his history of facilitating illicit financial transactions have cast a shadow over these dealings.
Senator Wyden’s staff has been investigating these payments for nearly two years, raising concerns about the role of financial institutions in enabling Epstein’s activities. The Senate Finance Committee’s memorandum has now recommended that the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) examine Bank of America’s handling of these transactions.
Money laundering experts note that delayed reporting of suspicious activity is not uncommon in the banking sector. U.S. financial institutions file millions of SARs annually, often after considerable time has passed since the transactions in question.
There are several reasons for these delays. Sometimes banks are unaware that transactions warrant investigation until much later. In other cases, institutions may hesitate to scrutinize affluent or high-profile clients for fear of damaging relationships.
In this case, however, the magnitude of the payments and Epstein’s well-documented history of financial and criminal misconduct have fueled criticism of Bank of America’s apparent inaction.
A spokesperson for Senator Wyden stated that he is reviewing the memorandum’s recommendations and plans to pursue further action. While it remains unclear what specific steps Congress or regulators might take, the case underscores the challenges financial institutions face in balancing customer relationships with regulatory compliance.
This isn’t the first time financial institutions have faced scrutiny over their ties to Epstein. Deutsche Bank, for instance, paid $150 million in fines in 2020 for its failure to properly monitor its relationship with Epstein, despite numerous red flags.
The Bank of America case highlights systemic issues within the financial industry, particularly in how banks handle transactions involving wealthy or influential clients. Critics argue that lax oversight and delayed reporting enable bad actors like Epstein to exploit the system.
While SARs are meant to alert regulators to suspicious activities, they do not constitute direct accusations of wrongdoing. However, delays in filing these reports can hinder law enforcement efforts to investigate and prevent crimes.
Senator Wyden’s investigation raises the possibility that Bank of America may have prioritized its business relationships over regulatory responsibilities, a claim that could lead to reputational damage and potential penalties for the institution.
The recommendations in the Senate Finance Committee’s memorandum call for heightened scrutiny of Bank of America’s actions by FinCEN. Should regulators find evidence of wrongdoing, the bank could face fines or other punitive measures.
The investigation also raises broader questions about the effectiveness of current anti-money laundering frameworks. If financial institutions continue to delay reporting suspicious activity involving high-profile clients, it undermines public trust in the system and the ability of authorities to hold powerful individuals accountable.
Bank of America’s delayed response to Epstein-related transactions is the latest chapter in the ongoing saga of how financial institutions handled his accounts. The case serves as a stark reminder of the need for stronger oversight and accountability in the banking industry, particularly when it comes to clients with known criminal associations.
Whether this investigation leads to significant reforms or punitive actions against the bank remains to be seen. What’s certain is that the American public and lawmakers alike are demanding greater transparency and responsibility from financial institutions entrusted with safeguarding the integrity of the nation’s financial system.
