Letters to Bette: Epstein Money Laundering
Retired IRS criminal investigator Martin Sheil Marty on why we need a Special ‘Epstein’ Prosecutor
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Author’s note: Retired IRS criminal investigator Martin Sheil, a Chicago resident, is a frequent contributor to Bette Dangerous.
Photo courtesy: Heidi Siegmund Cuda for Bette Dangerous
Letters to Bette: ‘Epstein Money Laundering’
by Martin Sheil
H,
By now I would presume you have seen the media reports with regard to Epstein making six-figure payments to associates who shall remain nameless… for now.
FYI, the main money laundering Statute Title 18 Section 1956 could have been used for prosecution purposes at the time, and in fact may still be available when it comes to the banks facilitating the payments.
If we make the rebuttable presumption that the payments emanating from Epstein's trust accounts represent proceeds from a Specified Unlawful Activity (SUA), then the payments to his associates would likely represent payments to “promote the SUA,” which for purposes of this exercise would be Human Trafficking. Further financial transactions entered into by Epstein could be viewed as either promoting the SUA or concealing the SUA.
The associates who received the payments from Epstein to promote the SUA could be viewed as conspirators in a Money Laundering Conspiracy.
Finally, the banks which processed the Epstein payments to the Epstein associates may have had and may still have potential exposure to money laundering charges.
Every commercial bank has an obligation under law to maintain an Anti-Money Laundering (AML) program where bank employees are trained to KYC — know your customer and spot financial transactions related to SUA activities.
Maintenance of a robust AML program protects the bank from money laundering charges. It is the AML program that triggers both currency transactions reports (CTRs) and Suspicious Activity Reports (SARs) to FinCEN — the Treasury Department's Financial Enforcement Center.
If the banks involved in processing the six-figure Epstein payments to Epstein associates filed Suspicious Activity Reports with FinCEN then Federal Law Enforcement, which has access to the SAR database contained within FinCEN, might have had an opportunity to investigate Epstein's human trafficking activities early on. By not filing SARs timely or after the fact, the banks evaded their AML obligations.
Did they do so knowingly? Intentionally?
Should the Feds explore these questions even now it is likely that they can get to the root of the monies deposited into Epstein's trust account and identify those folks paying Epstein substantial monies.
Such an investigation has excellent potential to, in fact, identify Epstein's “client list.”
We can see from the above narrative the two main prongs of money laundering or engaging in financial transactions for the purposes of:
Promotion of SUA activities, and
Concealment of SUA activities
Question of interest here: When the DOJ hides the identities of Epstein associates who received six-figure payments from Epstein are they not participating in the concealment prong of a money laundering conspiracy?
Given the sensitivity of the DOJ concealing the names of participants in a money laundering conspiracy and the presence of at least one major commercial bank at the heart of processing financial transactions involving human trafficking, should not a Special Prosecutor be designated to head up a money laundering investigation and potential prosecution of all those involved?
Inquiring minds want to know.
Thanks,
Martin Sheil
Supervisory Special Agent, IRS, Criminal Investigations, retired… for now.
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Thank you for sharing Marty's insightful letter. P.S. From the photo, it looks like his post-recovery regimen and dedication have paid off! He's looking well.