Epstein’s money, 2/4: the banks’ record

In March 2017, Deutsche Bank’s monitoring system generated an alert on a payment from Jeffrey Epstein to a Russian model and publicity agent. The alert was closed. Not because the bank had established the economic purpose of the payment, but because the activity was deemed “normal for this client”. Four words capture much of the banking record: repetition had normalised the risk.

Epstein’s banks were not operating in an information vacuum. JPMorgan filed its first suspicious activity report in 2002. Deutsche Bank classified him as high-risk when it onboarded him in 2013. Both institutions examined cash withdrawals, unusual counterparties and his reputation. Both also made explicit decisions to retain, restrict or terminate the relationship.

What the public record does not support matters just as much. An alert is not proof of an offence. A Suspicious Activity Report, or SAR, is neither an indictment nor a judgment. And a bank’s knowledge of a client’s conviction does not prove that each of its executives knew about each crime committed by that client.

The record establishes something else: signals existed, but their consequences remained limited for years; the largest reports were not filed until 2019, after Epstein’s new arrest.

As the first instalment showed, Epstein’s fortune cannot be reduced to a single number. Neither can his banking infrastructure. The JPMorgan, Deutsche Bank, BNY Mellon and Bank of America figures describe overlapping scopes. The same wire can be seen by the payer’s bank, the beneficiary’s bank and a correspondent bank. Adding them together produces a scandalous-looking number, not an accounting.

The exact scope of a SAR

The Bank Secrecy Act requires US banks to report certain transactions when they know, suspect or have reason to suspect that the activity may involve illegal funds, seek to evade reporting requirements or have no apparent business or lawful purpose. According to FinCEN, the clock starts when the institution initially detects facts that may form the basis for a filing: thirty days in principle, up to sixty when no suspect has yet been identified.

That detail rules out an easy shortcut. Comparing a transaction date with a SAR filing date does not, by itself, establish a late filing. The relevant date is when the bank concluded that the facts reached the reporting threshold. That chronology of detection, escalation and decision-making is almost never fully public.

SARs are also confidential. The available numbers come mainly from bank documents produced in litigation, regulatory orders and the investigation led by Senator Ron Wyden’s staff, who reviewed part of the Treasury file without being able to publish the reports in full. These are institutional and sometimes highly granular sources. They do not replace the missing transaction appendices.

JPMorgan: a first alert in 2002

The Senate Finance Committee staff report published on 4 August 2026 dates the main Epstein–JPMorgan relationship to 1998. An earlier memorandum focused on the bank breaks down nine SARs that have become partly public.

The first three were filed before the Palm Beach investigation:

18 April 2002: $194,300 in reported activity;
16 December 2002: $1,925,000;
15 April 2003: $166,600.

Four more reports were filed between 2008 and 2016. Together, the seven SARs preceding the two giant 2019 filings covered $4,316,424. JPMorgan can therefore say, accurately, that it began reporting transactions in 2002. But that early start raises the central question: how did a relationship already generating alerts survive until 2013, five years after Epstein’s Florida conviction?

The documents supply part of the answer. A 2003 internal review described the Epstein accounts as one of the private bank’s largest annual revenue flows. By September 2009, balances linked to the relationship stood at no less than $142 million. In 2012, he ranked among the private bank’s top twenty clients by revenue, eighth according to a record cited by investigators. Senate staff estimate that JPMorgan collected more than $8.1 million in fees from 2009 to 2014.

Revenue does not prove that a compliance decision was bought. It does establish that the risk was being weighed inside a commercially important relationship.

JPMorgan’s exit and Deutsche Bank’s onboarding overlap in August 2013. The timeline separates relationship decisions from SAR filing dates.

Seven million dollars in cash, year after year

An expert report submitted by the government of the US Virgin Islands identified 134 JPMorgan accounts connected to Epstein, his entities and his associates. That number comes from a party-appointed expert, not a judgment, but its annual cash table can be reconciled with internal records cited by Senate investigators.

From 2002 to 2013, the listed withdrawals total exactly $7,159,475. Cash was withdrawn in every year. The peak came in 2002 at $2,119,300, followed by $840,000 in 2004, $904,335 in 2005 and $938,264 in 2006, the year Epstein was arrested in Florida.

The series does not reveal who ultimately received each banknote. It documents a durable pattern that the bank observed in fragments.

In March 2012, banker John Duffy exchanged messages with risk personnel about $160,000 in withdrawals. He said that he had asked Epstein to use an aviation account rather than personal accounts, Epstein’s explanation being that the cash paid for fuel. Compliance would later write that paying cash for aircraft fuel abroad was not normal.

It would go too far to conclude from this that Duffy taught Epstein how to avoid a reporting requirement. The record establishes that withdrawals were shifted from one category of accounts to another, and that investigators identified no contemporaneous SAR. It does not document the legal intent required to establish evasion.

In July 2013, compliance discovered roughly $800,000 in prior withdrawals that had not been escalated to it. An employee asked why the business had not reported them. The question exposes an organisational divide: the bank held the data, but the units seeing it did not necessarily assign it the same meaning.

Exact sum of the annual series published in the Senate report and the Amador expert report. These withdrawals may overlap with SAR amounts and must not automatically be added to them.

In 2011, a decision to retain Epstein

The internal timeline becomes clearer from 2011. A due-diligence review recorded that Jes Staley had consulted Stephen Cutler, then the bank’s general counsel, and that a decision had been made to retain Epstein. In 2013, another review said that Mary Erdoes and John Duffy were aware of the relationship, which was classified as sensitive and subject to annual review.

JPMorgan has since isolated Staley’s conduct. In a two-page response to Senator Wyden, the bank said that its other executives had acted with integrity and that no material produced in discovery established that Jamie Dimon knew of the relationship before 2019. That response belongs in the account. Emails bearing references such as “pending Dimon review” underpin investigators’ questions, but do not by themselves prove that Dimon reviewed or approved any particular decision.

The direct relationship was closed in 2013 for risks connected, according to the Senate report, to money laundering and human trafficking. Yet on 14 August 2013, after the exit decision, Duffy asked Erdoes whether the bank could continue working with Epstein through third-party client accounts, including Leon Black’s. She approved.

That point connects the first two instalments of this investigation. The bank no longer retained Epstein as a direct client, but still authorised activity in which he acted as another client’s adviser. Closing a legal relationship did not necessarily remove every economic transaction that depended on it.

The billion that must not become $1.28 billion

After the July 2019 arrest, JPMorgan filed two reports on an entirely different scale.

On 13 August, an initial SAR covered 469 wires representing $200,979,535, over a period running from 1 October 2003 to 29 May 2019. On 26 September, a much broader filing covered 4,725 wires representing $1,081,819,653, from 1 October 2003 to 22 July 2019.

Their arithmetic sum is exactly $1,282,799,188. The Senate report’s table presents that addition. But the two periods begin on the same day and overlap almost entirely. Reuters described the September filing as an amended report that added 44 subjects and expanded the initial review.

Without the transaction lists, two boundaries are possible:

lower bound: $1,081,819,653, if the first set is wholly included in the second;
gross upper bound: $1,282,799,188, if the two sets are entirely separate.

The second assumption is difficult to reconcile with the nested dates and the description of an amended filing, but it cannot formally be eliminated without the appendices. The strongest wording is therefore: the expanded September 2019 SAR covered 4,725 wires worth $1.0818 billion; an earlier $200.98 million filing may overlap with it.

Even then, the billion is a cumulative face-value volume. It is not Epstein’s net worth, his income or proven criminal proceeds. A $10 million round trip counts as $20 million of transaction volume.

The Senate report adds the two amounts. Their calendar overlap and the description of the second filing as amended rule out presenting that sum as a deduplicated volume.

Deutsche Bank: onboarding a known risk

The handover came with almost no gap. A relationship manager who had moved from JPMorgan introduced Epstein to Deutsche Bank. The commercial memorandum projected $100 million to $300 million of flows and $2 million to $4 million in annual revenue. The onboarding file disclosed his conviction, registered-sex-offender status and seventeen civil settlements.

On 19 August 2013, Deutsche opened the first Southern Trust Company and Southern Financial accounts. More than forty accounts would ultimately be linked to Epstein, his entities and trusts. The client was classified as high-risk and treated as an “honorary PEP”, requiring enhanced scrutiny.

These facts come from the New York Department of Financial Services consent order, the strongest regulatory source in the banking record. It is a set of findings accepted by Deutsche Bank, not a civil litigant’s pleading.

The problem was not the absence of procedure. It was execution.

In January 2015, the reputational-risk committee agreed to continue the relationship after meeting Epstein. The order says that no minutes were kept, contrary to policy. Conditions were imposed, including enhanced monitoring of the accounts and transactions. Yet those conditions were communicated neither to the relationship manager nor to the transaction-monitoring team.

The committee could be, in the document’s words, “comfortable with things continuing”. The computer system did not know what that continuation was supposed to prohibit.

When abnormal activity becomes the client profile

The NYDFS order documents more than 120 wires, totalling $2.65 million, to Butterfly Trust beneficiaries. Their apparent purposes included hotels, rent and tuition. At least eighteen payments of $10,000 or more went to people described in the record as alleged co-conspirators. The bank also processed more than $7 million in apparent settlements to law firms and more than $6 million in other apparent legal expenses.

Taken individually, none of those payments proves a crime. Their significance lies in how the alerts were closed.

In March 2017, the payment to the Russian model or publicity agent was treated as normal for Epstein. In May 2018, a tuition wire to a person with an Eastern European surname and an account at a Russian bank received a two-part explanation: she was a friend and the money paid for her studies. According to the regulator, the bank asked no further questions.

The cash pattern is more concrete. From 2013 to 2017, one of Epstein’s lawyers made 97 withdrawals of $7,500 at the Park Avenue branch, totalling $727,500. That amount was the branch limit for third-party withdrawals. In 2014, the lawyer asked how frequently he could withdraw that sum without triggering an alert. In 2017, after an employee explained the reporting rule for amounts above $10,000, a larger withdrawal was split across two days.

The bank examined possible structuring, accepted the lawyer’s denial and allowed the withdrawals to continue. Including a $100,000 cash transaction in 2018, withdrawals exceeded $800,000 over the Deutsche relationship.

A termination letter was sent on 21 December 2018, after the renewed Miami Herald investigation. Despite that decision, the relationship manager drafted reference letters for two other financial institutions stating that he knew of no problems. Documents released since then indicate, according to Reuters, that some accounts and services remained active until the July 2019 arrest. The decision to exit, the notice and the operational closure of each account must therefore be treated as separate dates.

The 2026 Senate report attributes more than $250 million in wires from 2013 to 2019 to Deutsche Bank’s retrospective SARs. It cites one filing covering 1,140 wires and $147 million. That example sits inside the amount above $250 million; it is not an additional sum.

BNY Mellon: the same money at two banks

The January 2026 letter to BNY Mellon says that a 2019 filing identified 270 incoming and outgoing wires worth $378 million. According to notes taken by investigators during their Treasury review, the bank had found no clearly verifiable business purpose for the transactions.

The exact period and the list of all 270 wires are not public. The letter nevertheless supplies a decisive sample: eighteen round-number transfers of $1 million sent in 2007 from BNY accounts connected to Epstein or Financial Trust to JPMorgan accounts. The published table adds to $18 million; the letter refers to at least $20 million, indicating that the list is not exhaustive.

Another chain is still more revealing. On 15 June 2007, an Epstein account at BNY sent $7.4 million to Ghislaine Maxwell’s account at JPMorgan. The same day, $7.4 million was transferred to Air Ghislaine. Three days later, that company paid $7.3 million to Sikorsky as a helicopter deposit.

That is not three separate lots of $7.4 million in new money. It is a payment chain whose links can appear in more than one monitoring system.

The BNY letter and the Amador expert report trace this chain. It shows why aggregates from the sending and receiving banks cannot be added together.

Bank of America and the payer-side record

Bank of America occupied a different position. The records do not present it as Epstein’s main bank, but as the bank for Leon Black-controlled accounts that sent money to Financial Trust at JPMorgan and later Southern Trust at Deutsche Bank.

The Senate report reconstructs eighteen wires worth $169.8 million from 2012 to 2017. The first instalment explained why that figure does not equal the $158 million of fees retained by the Dechert review: it includes, among other amounts, $5.5 million in 2012 and $6.3 million in 2016, outside Dechert’s fee schedule.

For this article, the decisive information is the reporting date. According to Senate staff, Bank of America did not file the cited SARs until 2020, years after the wires and after Epstein’s death. The report says the bank could not identify a verifiable business purpose. Bank of America says that it did not facilitate Epstein’s crimes and that it takes its compliance obligations seriously.

The proposed $72.5 million class settlement with survivors has received only preliminary approval. As of 7 August 2026, the final hearing remains scheduled for 27 August. The bank denies wrongdoing. A civil settlement is not a SAR, a regulatory fine or an admission.

Penalties do not measure transaction flows

Three categories are routinely mixed together: reported transactions, regulatory penalties and civil settlements.

The NYDFS imposed a $150 million penalty on Deutsche Bank in 2020. That amount covered the Epstein matter alongside failures involving FBME Bank and Danske Bank Estonia. It cannot be assigned entirely to Epstein.

In 2023, JPMorgan agreed to a $290 million settlement in the survivors’ class action and a separate $75 million agreement with the US Virgin Islands. Deutsche Bank settled the class action against it for $75 million. Those agreements ended litigation without a trial on the merits and without a general admission of liability.

The case against BNY Mellon was dismissed with prejudice in February 2026 and an appeal was filed on 20 March. The dismissal means that the claims did not clear the legal threshold applied by the court. It does not certify the economic purpose of each of the 270 wires discussed in the Senate letter.

Finally, the FCA permanently barred Jes Staley from senior management roles and fined him roughly £1.1 million for approving a misleading letter about his closeness to and last contact with Epstein while he ran Barclays. That decision confirms the nature of their personal relationship. It is not a ruling on JPMorgan transaction flows.

Established alerts and remaining unknowns

The public record supports five propositions.

First, JPMorgan detected and reported transactions as early as 2002. The bank was therefore not devoid of signals before the 2008 conviction.

Second, identifiable decision-makers chose to retain Epstein in 2011, and in 2013 authorised some activity through third-party clients after closing his direct relationship.

Third, Deutsche Bank accepted a client whose history it knew, while anticipating large flows and revenues. It designed monitoring conditions that were not transmitted to the teams expected to apply them.

Fourth, both institutions processed years of cash patterns, trust transfers and foreign counterparties. The records do not prove that every operation was unlawful. They show that the activity generated enough questions to trigger reviews and alerts.

Fifth, the mass filings were retrospective. JPMorgan’s largest SAR came six years after the direct client exit. The giant reports attributed to Deutsche Bank, BNY Mellon and Bank of America followed the 2019 arrest.

The decisive material required to move from a history of controls to a complete accounting remains unavailable: each SAR’s transaction list, the included account identifiers, the exact dates of internal detection and the decisions connecting each alert to a filing or a decision not to file.

Reuters, which collected the banks’ responses to the 4 August 2026 report, said it could not independently verify all of its details. JPMorgan says that it reported transactions during and after the relationship and acted appropriately. Deutsche Bank says that it regrets the historical relationship, cooperated with authorities and addressed the deficiencies. Bank of America denies facilitating any crime.

Those responses do not dissolve the timeline. They establish its adversarial boundary.

The banking system did not simply “miss” Epstein. It observed him in fragments: a cash withdrawal here, a counterparty there, an annual review, a risk committee, a closed alert. Each fragment could receive an isolated explanation. Their organisational sum was reconstructed only after the fact.

The demonstrable scandal is therefore not a round number in the billions. It is the length of time during which known signals remained administratively compatible with continuing the business.

Read the French original.

Sources

Limitations

The Senate reports are institutional staff work produced under the Finance Committee’s ranking Democratic member. They draw partly on SARs reviewed in camera, but remain political reports rather than judgments. The NYDFS order is a set of regulatory findings accepted by Deutsche Bank. The Amador report is expert evidence submitted by a party to litigation. Civil allegations, settlements without admissions and procedural rulings are identified as such.

Bank aggregates are never added across institutions. The amounts measure reported transaction volumes, not Epstein’s income, net worth or established criminal proceeds. Corpus current to 7 August 2026.