Congress Named Three Banks on October 15. We Published the JPMorgan and Deutsche Bank Documents in February. Bank of America Is a Different Story.
On Wednesday, October 15, Democrats in both chambers introduced the Epstein Wall Street Records Act. Sen. Elizabeth Warren and Rep. Robert Garcia, the ranking Democrat on House Oversight, lead it, with Sens. Richard Blumenthal and Ron Wyden, the Oversight Democrats, and one Republican, Rep. Thomas Massie. Bloomberg and American Banker both reported the three banks at the center of it: JPMorganChase, Deutsche Bank and Bank of America.
We indexed the Justice Department's Epstein release earlier this year and put it online at epstein.dugganusa.com. Between February 4 and May 4 we published eight posts tracing JPMorgan and Deutsche Bank through those documents, with document IDs. We didn't find anything Congress couldn't. These are DOJ's public files, and all we did was make them searchable and read them. But one of the three banks never got a post from us. So I ran Bank of America through the index this morning. I expected a third JPMorgan. That isn't what's there.
What the bill does
The bill's text wasn't out when I wrote this, so this section relies on the sponsors' press release and on American Banker's account. The bill directs the Federal Reserve, the FDIC, the Comptroller of the Currency and the SEC to release their supervisory records on Epstein and his associates to Congress and the public. It requires them to investigate Epstein-connected banks and executives for possible banking, securities or illicit-finance violations. It provides for industry bars and civil penalties for executives who helped run his finances, and criminal referrals to the Justice Department where warranted.
Bloomberg's headline frames it as an agenda for "after midterms," and at least one report called it unlikely to pass this year. It follows an August 4 report from Senate Finance Committee Democrats, released by Wyden. NPR reported that it found "more than a dozen bankers at JPMorganChase, Bank of America and Deutsche Bank were aware" of suspicious Epstein transactions as far back as 2002.
The banks dispute that. JPMorgan wrote to Warren that the firm "did not facilitate or knowingly enable illegal activity" and said it cut ties with Epstein in 2013, per American Banker. Bank of America told NPR in August that "the bank did not facilitate wrongdoing." Deutsche Bank told NPR it regrets its historical connection to Epstein. Deutsche Bank and Bank of America declined to comment to American Banker on the bill.
The dates, side by side
Our posts on the three banks, against the bill's date of October 15, 2026:
Gates, JPMorgan and Project Molecule, February 4 (the post body says February 3). An August 2011 JPMorgan "Project Molecule - Client Draft" presentation, and Epstein's pitch to Jes Staley for a giving vehicle "initially just to the gates program, minimum gift 100 million."
The Davos Pipeline, February 6. Epstein to Staley on January 22, 2010 (EFTA01300430): "Darling is willing to sit with you and discuss these issues in Davos." Three days later (EFTA01300441): "I've set up you and peter to meet in davos with darling."
The Trustees, February 9. EFTA01266403 is the May 1, 2015 Amendment and Restatement of the Jeffrey E. Epstein 2014 Trust. It names "DARREN K. INDYKE, JAMES E. STALEY and DAVID MITCHELL, as Trustees." Staley ran JPMorgan's investment bank until 2013. The same post quoted EFTA02276796, Mary Erdoes of JPMorgan Asset Management in February 2019, on a referral: "we will definitley get her in the right hands."
Rome Was Burning, February 10. Staley to Epstein during the 2008 crisis (EFTA01300035): "The Private Bank has brought in $44 billion dollars in the last two weeks."
The Staley "Blackmail Ring" complaint, February 13. EFTA00019889 is an email from an unidentified sender to the chair of the UK Treasury Select Committee in February 2020. We reported it as unverified allegations, and it is still exactly that.
The Sberbank Pipeline, February 13. A wire to Russia that, per the post, "went through Deutsche Bank."
The Deutsche Bank Connection, February 15. Among other things, a February 25, 2014 wire of $100,067.96 to Hyperion Air, Inc. (EFTA01344209), and Epstein's November 11, 2016 schedule (EFTA02328937).
Account 40817840407000002066, May 4. Six years of payments to a Russian account, with JPMorgan Private Bank as the originator.
That's eight months, more or less, between our first post and the bill. That gap doesn't make us first. Lawsuits, the U.S. Virgin Islands case against JPMorgan, and years of reporting all got there long before any of us. All it shows is that the record was searchable and dated before Congress put it in a bill.
Bank of America: about 1,560 entries, and what they are
A phrase search for "Bank of America" returns about 1,559 index entries. Some documents appear in more than one DOJ dataset, so those collapse to 1,202 unique documents. I pulled every one, sorted them by what role Bank of America plays in the text, and then read samples from each group. The groups are approximate, since keyword rules miss things, but the shape is clear.
About 570 show Bank of America as the other bank in a payment. Most of them come from JPMorgan and Deutsche Bank records, not from Bank of America. A Deutsche Bank statement line reads "Outgoing Money Trnsf TO BANK OF AMERICA" (EFTA01285806). Wire reports list Bank of America's New York routing number as the receiving bank. A February 2013 JPMorgan statement for Southern Trust Company shows a CHIPS credit "Via: Bank of America, N.A." by order of "Leon D Black" (EFTA01548363). Black has said his payments to Epstein were for tax and estate-planning services, a 2021 review by the law firm Dechert found no evidence he knew of Epstein's crimes, and his spokesperson has said the transactions were lawful. When one of the largest banks in the country sits on the other end of a wire, that tells you where the other party banked. It doesn't tell you what Bank of America knew.
About 260 are Bank of America Corp. securities in someone's portfolio, things like "BANK OF AMERICA CORP 8 1/8% PFD STK" in a trust's fixed-income holdings (EFTA01549599), and dividend lines on a brokerage statement. That's an investment in the bank, not a relationship with it.
About 183 are miscellaneous, including personal Bank of America accounts belonging to people who received money from Epstein or his staff. We're not naming them. About 62 are court filings, case citations and news, many of them Florida court records that cite unrelated cases with "Bank of America" in the caption.
That leaves two small groups, and they're the story.
The bank that said no, and the bank that said yes
On December 3, 2013, Bank of America wrote to Jeffrey Epstein at East 71st Street. He had asked it to reconsider turning down his business credit card applications, and it turned him down again (EFTA02374105). It gave two reasons: "We are unable to verify financial information" and "You have adverse public record(s)." The letter then points him to the Justice Department's SMART Office, which runs the national sex offender registry. "We realize this is your second request," it says, "but we simply are unable to accommodate any extension of credit to you."
Two and a half years later, another part of the bank appears. On July 19, 2016, Richard Kahn, Epstein's accountant, forwards Epstein a market note from a Bank of America Merrill Lynch director and writes: "in process of setting up account with [the director] at investment bank now" (EFTA02457677). The same director had covered Epstein's accounts at JPMorgan through at least 2013. The index has 74 entries under that name, and most of the 2016 and 2017 ones are trade ideas sent to Epstein and Kahn. On April 19, 2017, one of them pitches a VIX trade and adds: "We can't trade this in your account here at BAML since we don't have margin" (EFTA02391868). A Deutsche Bank relationship memo from the same period says plainly: "In addition to DB, he has relationships with MS and BAML" (EFTA01386055).
So the release shows Bank of America's card side refusing Epstein credit in 2013 and citing the sex offender registry, and its Merrill Lynch investment bank opening an account for his side in 2016. We don't know what review Merrill ran, what the account held, or when it closed. None of that is in the release. That gap is the kind of thing the bill's supervisory-records provision would fill, if it ever passes.
Ten documents: the subpoenas
The smallest group is ten documents of legal process, and the dates are hard to ignore.
August 17, 2019, one week after Epstein died in federal custody. A Southern District of New York grand jury subpoena goes to Bank of America's Legal Order Processing unit in Wilmington (EFTA00027219, with an OCR copy at jp2_page_30376). It cites 18 U.S.C. 201, 371, 1001, 1346 and 1519, which cover bribery, conspiracy, false statements, honest-services fraud and falsification of records. It asks for records from January 1, 2019 onward. The account it targets is redacted, and the documents don't say whose it is. Two discovery letters dated December 31, 2019, in the case against the two Metropolitan Correctional Center officers on duty the night he died (United States v. Noel and United States v. Thomas, No. 19 Cr. 830), list "Financial records produced by Bank of America" among records from eight institutions (EFTA00027732, EFTA00025239). Both officers admitted falsifying records, entered deferred-prosecution agreements in 2021, and had the charges dismissed after complying. Whether the August subpoena and those records belong together, the release doesn't say.
October 15, 2019, seven years to the day before the bill. A second SDNY grand jury subpoena goes to Bank of America, signed by then-U.S. Attorney Geoffrey S. Berman (EFTA00019750 through EFTA00019754, with a second copy of the rider at EFTA00019755). This one cites 18 U.S.C. 1591, 1594(c), 2422(b) and 371, the sex-trafficking, trafficking-conspiracy and enticement statutes. It asks for every record "from account inception to the present," including signature cards, "Know your customer" documentation, wire records, safe deposit records and online banking IP logs. The return date was October 29, 2019, to the FBI in New York, and the cover letter asks the bank not to tell anyone. The names on the rider are redacted.
August 5, 2020, the government's first discovery letter to Ghislaine Maxwell's lawyers in United States v. Maxwell, 20 Cr. 330, lists "Bank of America Records" at Bates SDNY_GM_00003701 to 00003702 (EFTA00040593).
What isn't there
JPMorgan's own production is all over this release. About 45,800 index entries carry its JPM-SDNY Bates stamp and the legend "Confidential Treatment Requested by JPMorgan Chase." About 19,900 carry Deutsche Bank's DB-SDNY stamp. Those counts are larger than the entries that literally say "Deutsche Bank," because statements and check images often don't print the bank's full name. Overall, "JPMorgan" appears in about 52,500 entries, "JP Morgan" in about 9,300 more, and "Deutsche Bank" in about 11,900.
For Bank of America, I found no production stamp at all. The one apparent "BOA-SDNY" hit turns out to be an OCR misread of a Deutsche Bank page. So the release contains the subpoenas sent to Bank of America and an index line saying Bank of America records exist, but not, as far as our copy shows, the records themselves. Either DOJ didn't release them or they're in a form we haven't recognized. We're 95% sure of the count and much less sure of the reason.
That's the honest finding on the third bank. Most of its 1,559 entries are mundane: it shows up because everyone wires money to Bank of America. The few that aren't mundane are a 2013 credit refusal, a 2016 investment-bank account, and two grand jury subpoenas whose answers aren't in the public file.
What we did, and didn't
We didn't break this story. Lawyers, reporters, the Virgin Islands and two congressional committees have been on these banks for years. What we can show is a searchable copy of DOJ's release and dated posts that cite document IDs anyone can check. If the Fed, the OCC, the FDIC and the SEC ever release their supervisory files, the first thing I'll do is run them against the IDs in this post.
Nothing here says any bank, banker or named person committed a crime. Appearing in Epstein's financial records is documented contact. It isn't evidence of wrongdoing. Every bank named here has denied facilitating illegal activity.
Search the documents yourself at epstein.dugganusa.com. Try the phrase "Legal Order Processing," or "here at BAML," or any EFTA ID above, and you'll get what we got.
Primary sources: House Oversight Democrats press release, October 15, 2026; American Banker, October 15, 2026; Bloomberg, October 15, 2026; NPR, August 4, 2026, on the Senate Finance Democrats' report; the Justice Department's Epstein release as indexed at epstein.dugganusa.com (EFTA IDs cited inline).
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