Title 31 of the U.S. Code mandates banks to conduct due diligence on high-value accounts and timely report suspicious transactions via Suspicious Activity Reports (SARs). In Epstein’s case, investigations reveal that major banks—like JPMorgan Chase and Deutsche Bank—processed vast and unusual transactions tied to him with significant delays or not at all. Senator Ron Wyden cited internal bank records showing one bank flagged more than $170 million flowing to Epstein, but only reported it seven years late, long after Epstein's death in 2019. SARs involving installments up to $100 million and Russian-linked wire transfers reportedly went undisclosed or underreported, suggesting systemic circumvention of Title 31 requirements.


These failures weren’t just clerical missteps—they represented institutional lapses in AML enforcement. Deutsche Bank was fined $150 million in 2020 for ignoring red flags and maintaining numerous Epstein-linked accounts well into 2019, despite clear indicators of his illicit activities. Compliance officers reportedly raised concerns, only to be overridden by bank executives, allowing Epstein’s atypical cash movements and hidden financial networks to persist unchallenged until after media scrutiny intensified.


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source:

https://lawandcrime.com/high-profile/brutal-rebuke-of-deutsche-bank-raises-serious-questions-about-one-of-jeffrey-epsteins-lawyers/

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