Bank of New York Mellon

Bank of New York Mellon processed 270 wire transfers totaling $378 million through Jeffrey Epstein's accounts — transactions the bank's own 2019 disclosure conceded it could not assign a legitimate business purpose to — without filing a single Suspicious Activity Report with the Treasury Department at the time they occurred.

That decade-plus reporting gap became the target of a Senate Finance Committee investigation led by Ranking Member Ron Wyden (D-OR), who on January 15, 2026 wrote to BNY CEO Robin Vince demanding account records, KYC files, and the names of every relationship manager who touched the Epstein book between 2003 and 2019.¹ The letter arrived two weeks before a federal judge dismissed the civil trafficking lawsuit against BNY with prejudice — a legal victory for the bank that did nothing to resolve the regulatory question of whether its silence violated the Bank Secrecy Act.²

  The 2019 Filing and What It Showed

The immediate hook for Wyden's inquiry was a disclosure BNY made to the government in 2019, the year Epstein died in federal custody awaiting trial on sex-trafficking charges. In that filing the bank retroactively flagged 270 wire transfers totaling $378 million as suspicious — transactions it had processed without contemporaneous SAR filings over the preceding years. The Bank Secrecy Act requires financial institutions to file SARs within thirty days of detecting a suspicious transaction; BNY's filing, by definition, came years late for most of those movements.

Wyden's letter singled out one pattern as particularly glaring: eighteen wire transfers of exactly $1 million each, sent during 2007 from Epstein's BNY accounts to accounts he controlled at JPMorgan Chase.¹ Round-dollar transfers between accounts held by the same beneficial owner, with no documented business rationale, represent one of the most elementary structuring red flags in AML compliance practice. That BNY processed eighteen such transfers in a single calendar year and did not file a SAR contemporaneously is, in Wyden's framing, a potential violation of the Act rather than merely a lapse in judgment.

  Wyden's Broader "Follow the Money" Investigation

The BNY letter was not a standalone inquiry. Wyden's Senate Finance Committee spent three years reviewing Treasury Department files on Epstein's financial network and by mid-2025 had documented approximately 4,725 wire transfers flowing in and out of a single Epstein JPMorgan account, totaling roughly $1.1 billion.³ Those Treasury SAR records span multiple institutions and time periods; the BNY probe extended that investigation to a bank whose relationship with Epstein has received less public scrutiny than JPMorgan or Deutsche Bank.

For a broader account of JPMorgan's fifteen-year private-banking relationship with Epstein, which generated more than $290 million in victim settlements, see JPMorgan Chase. For Deutsche Bank's role after JPMorgan exited in 2013 — a six-year relationship that ended in a $150 million New York state fine — see Deutsche Bank.

  The Aggregate Figure Discrepancy

Two numbers appear in public reporting and they have not been reconciled. Wyden cited approximately $1.1 billion flowing through a single JPMorgan account in floor remarks and in Senate Finance Committee releases.³ A separate figure — roughly $1.5 billion — appears in accounts referencing aggregate post-arrest SAR filings from four institutions: JPMorgan Chase, Deutsche Bank, Bank of New York Mellon, and Bank of America.⁴ The gap is real and its source is methodological: the $1.1 billion figure covers one account at one bank over a defined period; the $1.5 billion appears to represent a broader cross-institution tally that includes the $378 million BNY now acknowledges. Neither figure has been formally reconciled in a public document, and Treasury Secretary Scott Bessent refused throughout 2025 to turn the SAR files over to Wyden's committee, downplaying their significance.⁵ A Republican senator blocked the Produce Epstein Treasury Records Act on the Senate floor on March 3, 2026, preventing a legislative mandate that would have compelled disclosure.⁵

  BNY's Legal Defense and the Rakoff Ruling

BNY's institutional position, stated publicly after class-action suits were filed in October 2025, was that "Jeffrey Epstein was never a direct client" of the bank.² The transfers at issue moved through entities and accounts associated with Epstein rather than accounts held in his personal name — a distinction the bank deployed to argue it lacked the client-level visibility that AML obligations typically presuppose. On January 29, 2026, U.S. District Judge Jed Rakoff dismissed all claims against BNY with prejudice, finding the complaint did not sufficiently allege the bank was aware of Epstein's activities.² The dismissal resolved civil liability but left the regulatory question — whether the retroactive 2019 SAR filing satisfied Bank Secrecy Act obligations for transactions that should have been reported years earlier — unanswered.

The contrast with Bank of America is instructive. Rakoff allowed claims against Bank of America to proceed in the same January 2026 ruling; BofA subsequently settled for $72.5 million in March 2026, without admitting liability.⁶

  Compliance Failures in Context

The pattern Wyden identified at BNY mirrors what regulators and litigants documented at Deutsche Bank: transactions that should have triggered enhanced due diligence and contemporaneous SAR filings were processed without meaningful review, with the institution's disclosure arriving only after Epstein's arrest made continued silence legally untenable. Deutsche Bank paid $150 million to New York state regulators in July 2020 for analogous failures; no equivalent enforcement action against BNY had been announced as of the date of this writing.

Wyden's demand letter asked BNY to produce, by February 6, 2026: the names and supervisors of every relationship manager involved with Epstein-linked accounts; KYC profiles maintained for those accounts from 2003 through 2019; records of any cash withdrawals exceeding $10,000; and documentation of any internal investigation the bank conducted after its 2019 filing.¹ BNY's response, if any, had not been made public as of mid-2026.

  Timeline

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  References

  Footnotes

1. BNY's $378 Million of Epstein Transfers Draws Senator's Scrutiny, Bloomberg Law ↩ ↩² ↩³

2. BNY Dismissed from Epstein Case, but BofA Must Face Some Claims, Banking Dive ↩ ↩² ↩³

3. User Clip: Sen. Ron Wyden says 'follow the money' on Epstein, cites $1.1 billion in wire transfers, C-SPAN ↩ ↩²

4. Social media posts claim Trump made 4,725 wire transfers to Epstein. That misrepresents Senate probe, PolitiFact ↩

5. Senate Republican Blocks Wyden Bill Mandating Treasury Hand Over Epstein Bank Records, Senate Finance Committee ↩ ↩²

6. Bank of America Agrees to Pay $72.5M to Settle Epstein Accusers' Lawsuit, Insurance Journal ↩