It is hard to believe the police first began investigating Jeffrey Epstein more than two decades ago given the severity and depth of the convicted sex offender’s crimes are only now really beginning to be understood.
More than 21 years after Palm Beach police launched an inquiry into the disgraced financier after the family of a 14-year-old girl reported she was molested at his US mansion in 2005, the publication of millions of previously unreleased documents by the Department of Justice has reignited the public’s interest in the scandal.
The release of the 3mn additional pages of documents by the DoJ on January 30 reveal that some of the world’s most powerful people, the likes of Donald Trump, Elon Musk, Andrew Mountbatten-Windsor and Bill Gates, had exceptionally close ties with Epstein. But bankers and the banks they worked for also feature heavily.
Indeed, senior banking executives linked to the former hedge fund manager are coming under intense pressure to keep hold of their jobs, with a top lawyer at Goldman Sachs the latest to resign after the files showed she and Epstein maintained close ties long after he was convicted in a Florida courtroom in 2008 for procuring a minor for prostitution. In 2011, he was additionally placed on the New York sex offenders registry at “Level 3”, a life-long designation that indicates a “high risk of repeat offence and a threat to public safety”.
Kathy Ruemmler, a senior lawyer at the Wall Street bank and former White House counsel to Barack Obama, said on February 12 that she will quit Goldman in June.
Ruemmler said in a statement: “I made the determination that the media attention on me, relating to my prior work as a defence attorney, was becoming a distraction.”
Her departure will no doubt intensify calls on the many other bankers named in the DoJ documents to step down and add to the list of senior figures forced to depart their companies — a list that includes Jes Staley, the former chief executive of Barclays. Staley stepped aside as boss of the UK lender in 2021 following an investigation into his links with Epstein by the Financial Conduct Authority.
JPMorgan, meanwhile, who Staley previously worked for, appears more than a thousand times in the files, with the US bank continuing to be drawn into the scandal.
“It’s never just one bad person,” Bridgette Carr, a human-trafficking expert at the University of Michigan Law School, told a BBC investigation about flights linked to Epstein to and from the UK where women said they were abused. “You don’t think about the accountant and the lawyer and the banker — or all the bankers — and all these people that had to implicitly, and sometimes explicitly, be OK with what was happening for it to continue.”
David Gibson-Moore, a strategic adviser who has spent decades in investment banking, adds: “The release of the DoJ files has placed major financial institutions under heavy scrutiny, with JPMorgan featuring prominently. The scale of references [within the documents] raises not only reputational concerns but broader questions about governance, incentives and institutional judgment.”
Ruemmler appeared in numerous emails with Epstein and his associates from 2014 to 2019. Various emails suggest she often visited Epstein for lunch, that he showered her with gifts and sometimes paid for hair appointments.
Research from The Banker shows a number of other senior bankers had very close ties with Epstein, including Mary Erdoes, JPMorgan’s current chief executive of asset and wealth management.
In August 2011, Epstein emailed Staley and Erdoes about “the French bank rumor problem” referencing market talk that Société Générale was in serious financial difficulties and had held an emergency meeting with France’s then-president Nicolas Sarkozy. Erdoes replied: “We are trying to stem rumors ourselves.”
Erdoes also sent emails of a more personal nature from her JPMorgan email address on multiple occasions, for example, wishing Epstein a “great birthda= [sic] weekend” in January 2012.
In 2019, an email from Epstein’s assistant asked Erdoes to handle Ruemmler’s private banking, describing the Goldman employee as a “powerful woman”.
“Jeffrey wanted me to reach out to you [about] his very good friend and former White House counsel to [President] Barak Obama [sic], Kathy Ruemmler. She would like to open an account with JPM. Jeffrey requests she deal with you personally. Might this be possible?” the email read.
“. . . we will definitley [sic] get her in the right hands,” Erdoes replied.
The interactions reveal how banking was an integral part of Epstein’s network. And as is now apparent, thousands of suspicious payments and transfers, which should have been flagged and a cause for concern, were carried out by his lenders.
A November report by the US Senate Committee on Finance, for example, questioned whether “Epstein’s accounts were truly subject to enhanced monitoring by [JPMorgan]” because if that had been the case, “it seems highly unlikely the bank would have failed to contemporaneously detect over 5,000 suspicious wire transfers”.
Reassurances about Epstein’s requests, and even his standing as a client, seem to have been based on the personal judgment of a very few people at JPMorgan and, later, Deutsche Bank — his main private banks.
The November report noted that, according to a 2011 internal due diligence document, “Staley conferred with Stephen Cutler [then JPMorgan’s general counsel] and the decision was made to keep Mr. Epstein as a PB [private banking] client.”
Brett Erickson, a financial crime and compliance specialist and managing principal of US-based Obsidian Risk Advisors, calls it a “leadership failure”.
He says: “This was not a case of banks lacking tools. It was a case of governance discipline breaking down. There were clear warning signs and behaviour that, in almost any other context, would have resulted in a client being exited.”
Staley had been in charge of JPMorgan’s asset and wealth management between 2001 and 2009. He then went on to head the investment banking arm until he left the lender in January 2013 — the same year the US bank cut Epstein off as a private banking client.
A board member at a large European bank tries to explain perhaps why Epstein remained as a customer. They told The Banker: “Somebody raises a red flag, puts [the client] on the exit list and it goes higher up the chain, and then people probably look at the income on this account. It’s a trade off, risk versus return.”
Erickson adds: “In this case, the relationship appears to have been viewed as commercially valuable enough that the perceived upside outweighed the perceived downside. The problem is that reputational and regulatory downside is often mispriced or fundamentally misunderstood.”
So what lessons could and should banks and their bankers learn from the scandal and what must lenders do now to ensure that governance frameworks function when it matters most?
To answer this Gibson-Moore suggests banks need to pose themselves a further set of questions: “Does the risk oversight function have the authority to override commercial considerations? Who has clear authority to terminate a relationship? Are escalation channels protected and independent? Does the board receive unfiltered reporting on reputational exposure? And are whistleblower protections in place?”
He says banks “must embed forward looking reputational assessment” into client onboarding and thoroughly review existing processes for high risk relationships.
“Incentives must be recalibrated so that compliance and conduct carry equal weight to revenue in pay and promotion. Reputational concerns should be documented and escalated transparently up to board level if necessary. Finally, banks must foster a culture in which raising concerns is protected and rewarded, not sidelined. Sound governance requires that scrutiny be applied equally no matter how senior or influential the client,” Gibson-Moore told The Banker.
Erickson agrees. “In financial crime, the assumption that ‘it won’t happen to us’ is no longer credible. Human trafficking, money laundering, sanctions exposure, and fraud have become too complex and too interconnected. The responsible posture for any institution in 2026 is to assume exposure and plan accordingly.”
Until that happens the mistakes highlighted in the DoJ files will be made. Indeed, the documents show Chip Packard, former Americas wealth management head at Deutsche Asset and Wealth Management, was instrumental in approving the onboarding of Epstein as a client for the bank in 2013.
Packard wrote in a May 2013 email with the subject heading “Epstein”: “Spoke with both [John] Caruso and [Joseph] Polizzotto [Deutsche Bank’s general counsel at the time]. Neither suggests this requires rep risk and we can move ahead so long as nothing further is identified through KYC [know your client] and AML [anti-money laundering] client adoption.” Caruso supervised Deutsche Bank’s AML programme in the US.
However, in an internal memo seen by the FT in 2020, Deutsche Bank chief executive Christian Sewing later said: “Onboarding [Epstein] as a client in 2013 was a critical mistake and should never have happened,” given the financier was designated a “high risk” customer by the bank.
In July 2020, the German bank agreed to pay a $150mn fine for compliance failings in its dealings with Epstein and other matters. Packard left the firm in March 2016.
These types of failures exemplify why “risk management should be independent”, according to Evgueni Ivantsov, chair of the European Risk Management Council, who advocates for a risk function that ultimately reports to the board, not the CEO.
He says he lobbied for such a solution among ERMC members, which include chief risk officers of large international banks, as recently as a couple of years ago, although he had little success. Many risk officers continue to see the benefits of being part of the business and not feeling detached from it, Ivantsov says. But such a separation, he adds, would also help deal with other “uncomfortable” scenarios that banks would be advised to consider.
He cites a fictitious example of action needing to be taken by those lower down the pecking order if a CEO is found to be corrupt. “This scenario has no chance of being approved because who will approve it if you are part of the CEO reporting line?”
“You cannot accept the presents, the private jets. That’s how it starts, and years later you’re implicated.”
A board member overseeing risk at a global bank agrees: “As long as the risk function ultimately reports to the CEO, someone in the business will always be able to override what someone in compliance or risk is warning about.”
Greater regulatory action could work as a deterrent, they say, adding that the fear of irreparable damage to one’s career is another disincentive. Failure to deal appropriately with serious issues, once exposed, leaves a stain.
“If anybody [from our bank] became visible in the [Epstein] files, we would have a bloody good look at them. I would be astonished if any bank wouldn’t,” the board member told The Banker.
If anyone, including investors and regulators, queried that person’s presence in the files and asked “what are you doing about it?”, “I’d want to be ready with an answer”, they add.
Even if repercussions, so far, have been minimal on a company level, banks may wish to reconsider the organisational structure of their risk function. At a personal level, where reputational cost is ultimately paid, the solution to the problem may be very simple. “The only way to avoid that kind of stuff is to not take the meeting” in the first place, says a former bank CEO.
“I’ve never seen an honest person convert a corrupt one; it’s the corrupt who convert the honest. You cannot meet them. You cannot accept the presents, the private jets. That’s how it starts, and years later you’re implicated.”
Gibson-Moore adds in closing: “The Epstein files are less about one client than about institutional blind spots generally. Banks will survive this episode. What matters now is whether they fully address the underlying misalignments rather than merely trying to weather the headlines.”
Additional reporting by Anita Hawser, Aliya Shibli and Gabriel Whitwam
It is hard to believe the police first began investigating Jeffrey Epstein more than two decades ago given the severity and depth of the convicted sex offender’s crimes are only now really beginning to be understood.
More than 21 years after Palm Beach police launched an inquiry into the disgraced financier after the family of a 14-year-old girl reported she was molested at his US mansion in 2005, the publication of millions of previously unreleased documents by the Department of Justice has reignited the public’s interest in the scandal.
The release of the 3mn additional pages of documents by the DoJ on January 30 reveal that some of the world’s most powerful people, the likes of Donald Trump, Elon Musk, Andrew Mountbatten-Windsor and Bill Gates, had exceptionally close ties with Epstein. But bankers and the banks they worked for also feature heavily.
Indeed, senior banking executives linked to the former hedge fund manager are coming under intense pressure to keep hold of their jobs, with a top lawyer at Goldman Sachs the latest to resign after the files showed she and Epstein maintained close ties long after he was convicted in a Florida courtroom in 2008 for procuring a minor for prostitution. In 2011, he was additionally placed on the New York sex offenders registry at “Level 3”, a life-long designation that indicates a “high risk of repeat offence and a threat to public safety”.
Kathy Ruemmler, a senior lawyer at the Wall Street bank and former White House counsel to Barack Obama, said on February 12 that she will quit Goldman in June.
Ruemmler said in a statement: “I made the determination that the media attention on me, relating to my prior work as a defence attorney, was becoming a distraction.”
Her departure will no doubt intensify calls on the many other bankers named in the DoJ documents to step down and add to the list of senior figures forced to depart their companies — a list that includes Jes Staley, the former chief executive of Barclays. Staley stepped aside as boss of the UK lender in 2021 following an investigation into his links with Epstein by the Financial Conduct Authority.
JPMorgan, meanwhile, who Staley previously worked for, appears more than a thousand times in the files, with the US bank continuing to be drawn into the scandal.
“It’s never just one bad person,” Bridgette Carr, a human-trafficking expert at the University of Michigan Law School, told a BBC investigation about flights linked to Epstein to and from the UK where women said they were abused. “You don’t think about the accountant and the lawyer and the banker — or all the bankers — and all these people that had to implicitly, and sometimes explicitly, be OK with what was happening for it to continue.”
David Gibson-Moore, a strategic adviser who has spent decades in investment banking, adds: “The release of the DoJ files has placed major financial institutions under heavy scrutiny, with JPMorgan featuring prominently. The scale of references [within the documents] raises not only reputational concerns but broader questions about governance, incentives and institutional judgment.”
Ruemmler appeared in numerous emails with Epstein and his associates from 2014 to 2019. Various emails suggest she often visited Epstein for lunch, that he showered her with gifts and sometimes paid for hair appointments.
Research from The Banker shows a number of other senior bankers had very close ties with Epstein, including Mary Erdoes, JPMorgan’s current chief executive of asset and wealth management.
In August 2011, Epstein emailed Staley and Erdoes about “the French bank rumor problem” referencing market talk that Société Générale was in serious financial difficulties and had held an emergency meeting with France’s then-president Nicolas Sarkozy. Erdoes replied: “We are trying to stem rumors ourselves.”
Erdoes also sent emails of a more personal nature from her JPMorgan email address on multiple occasions, for example, wishing Epstein a “great birthda= [sic] weekend” in January 2012.
In 2019, an email from Epstein’s assistant asked Erdoes to handle Ruemmler’s private banking, describing the Goldman employee as a “powerful woman”.
“Jeffrey wanted me to reach out to you [about] his very good friend and former White House counsel to [President] Barak Obama [sic], Kathy Ruemmler. She would like to open an account with JPM. Jeffrey requests she deal with you personally. Might this be possible?” the email read.
“. . . we will definitley [sic] get her in the right hands,” Erdoes replied.
The interactions reveal how banking was an integral part of Epstein’s network. And as is now apparent, thousands of suspicious payments and transfers, which should have been flagged and a cause for concern, were carried out by his lenders.
A November report by the US Senate Committee on Finance, for example, questioned whether “Epstein’s accounts were truly subject to enhanced monitoring by [JPMorgan]” because if that had been the case, “it seems highly unlikely the bank would have failed to contemporaneously detect over 5,000 suspicious wire transfers”.
Reassurances about Epstein’s requests, and even his standing as a client, seem to have been based on the personal judgment of a very few people at JPMorgan and, later, Deutsche Bank — his main private banks.
The November report noted that, according to a 2011 internal due diligence document, “Staley conferred with Stephen Cutler [then JPMorgan’s general counsel] and the decision was made to keep Mr. Epstein as a PB [private banking] client.”
Brett Erickson, a financial crime and compliance specialist and managing principal of US-based Obsidian Risk Advisors, calls it a “leadership failure”.
He says: “This was not a case of banks lacking tools. It was a case of governance discipline breaking down. There were clear warning signs and behaviour that, in almost any other context, would have resulted in a client being exited.”
Staley had been in charge of JPMorgan’s asset and wealth management between 2001 and 2009. He then went on to head the investment banking arm until he left the lender in January 2013 — the same year the US bank cut Epstein off as a private banking client.
A board member at a large European bank tries to explain perhaps why Epstein remained as a customer. They told The Banker: “Somebody raises a red flag, puts [the client] on the exit list and it goes higher up the chain, and then people probably look at the income on this account. It’s a trade off, risk versus return.”
Erickson adds: “In this case, the relationship appears to have been viewed as commercially valuable enough that the perceived upside outweighed the perceived downside. The problem is that reputational and regulatory downside is often mispriced or fundamentally misunderstood.”
So what lessons could and should banks and their bankers learn from the scandal and what must lenders do now to ensure that governance frameworks function when it matters most?
To answer this Gibson-Moore suggests banks need to pose themselves a further set of questions: “Does the risk oversight function have the authority to override commercial considerations? Who has clear authority to terminate a relationship? Are escalation channels protected and independent? Does the board receive unfiltered reporting on reputational exposure? And are whistleblower protections in place?”
He says banks “must embed forward looking reputational assessment” into client onboarding and thoroughly review existing processes for high risk relationships.
“Incentives must be recalibrated so that compliance and conduct carry equal weight to revenue in pay and promotion. Reputational concerns should be documented and escalated transparently up to board level if necessary. Finally, banks must foster a culture in which raising concerns is protected and rewarded, not sidelined. Sound governance requires that scrutiny be applied equally no matter how senior or influential the client,” Gibson-Moore told The Banker.
Erickson agrees. “In financial crime, the assumption that ‘it won’t happen to us’ is no longer credible. Human trafficking, money laundering, sanctions exposure, and fraud have become too complex and too interconnected. The responsible posture for any institution in 2026 is to assume exposure and plan accordingly.”
Until that happens the mistakes highlighted in the DoJ files will be made. Indeed, the documents show Chip Packard, former Americas wealth management head at Deutsche Asset and Wealth Management, was instrumental in approving the onboarding of Epstein as a client for the bank in 2013.
Packard wrote in a May 2013 email with the subject heading “Epstein”: “Spoke with both [John] Caruso and [Joseph] Polizzotto [Deutsche Bank’s general counsel at the time]. Neither suggests this requires rep risk and we can move ahead so long as nothing further is identified through KYC [know your client] and AML [anti-money laundering] client adoption.” Caruso supervised Deutsche Bank’s AML programme in the US.
However, in an internal memo seen by the FT in 2020, Deutsche Bank chief executive Christian Sewing later said: “Onboarding [Epstein] as a client in 2013 was a critical mistake and should never have happened,” given the financier was designated a “high risk” customer by the bank.
In July 2020, the German bank agreed to pay a $150mn fine for compliance failings in its dealings with Epstein and other matters. Packard left the firm in March 2016.
These types of failures exemplify why “risk management should be independent”, according to Evgueni Ivantsov, chair of the European Risk Management Council, who advocates for a risk function that ultimately reports to the board, not the CEO.
He says he lobbied for such a solution among ERMC members, which include chief risk officers of large international banks, as recently as a couple of years ago, although he had little success. Many risk officers continue to see the benefits of being part of the business and not feeling detached from it, Ivantsov says. But such a separation, he adds, would also help deal with other “uncomfortable” scenarios that banks would be advised to consider.
He cites a fictitious example of action needing to be taken by those lower down the pecking order if a CEO is found to be corrupt. “This scenario has no chance of being approved because who will approve it if you are part of the CEO reporting line?”
“You cannot accept the presents, the private jets. That’s how it starts, and years later you’re implicated.”
A board member overseeing risk at a global bank agrees: “As long as the risk function ultimately reports to the CEO, someone in the business will always be able to override what someone in compliance or risk is warning about.”
Greater regulatory action could work as a deterrent, they say, adding that the fear of irreparable damage to one’s career is another disincentive. Failure to deal appropriately with serious issues, once exposed, leaves a stain.
“If anybody [from our bank] became visible in the [Epstein] files, we would have a bloody good look at them. I would be astonished if any bank wouldn’t,” the board member told The Banker.
If anyone, including investors and regulators, queried that person’s presence in the files and asked “what are you doing about it?”, “I’d want to be ready with an answer”, they add.
Even if repercussions, so far, have been minimal on a company level, banks may wish to reconsider the organisational structure of their risk function. At a personal level, where reputational cost is ultimately paid, the solution to the problem may be very simple. “The only way to avoid that kind of stuff is to not take the meeting” in the first place, says a former bank CEO.
“I’ve never seen an honest person convert a corrupt one; it’s the corrupt who convert the honest. You cannot meet them. You cannot accept the presents, the private jets. That’s how it starts, and years later you’re implicated.”
Gibson-Moore adds in closing: “The Epstein files are less about one client than about institutional blind spots generally. Banks will survive this episode. What matters now is whether they fully address the underlying misalignments rather than merely trying to weather the headlines.”
Additional reporting by Anita Hawser, Aliya Shibli and Gabriel Whitwam
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