All Epstein KYC/AML Case Study articles
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AnalysisEpstein victim Giuffre’s death by suicide reminds us of the human stakes in compliance
Virgina Giuffre, a victim of Jeffrey Epstein’s sex-trafficking ring and the first of Epstein’s victims to go public in 2015, died by suicide on Friday. Her death is a stark reminder of the all-too-human cost of professional negligence.
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NewsChapter 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.
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NewsChapter 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.
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NewsChapter 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.
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NewsChapter 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.
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NewsCase 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.