institutions act as a critical line of defense against illegal financial transactions in an ever changing and interconnected financial network. 2. The Federal Bank Secrecy Act ("BSA") requires financial institutions to have adequate anti-money laundering ("AML") policies and systems in place. New York State law requires f

n in 2013. C. JP Morgan's Role in the Sex-Trafficking Venture 1. Banking laws and regulations exist to prevent funding of criminal ventures. 116. The Federal Bank Secrecy Act ("BSA") requires financial institutions 30 EFTA00162150 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 31 of 130 to have adequate anti-m

al behavior in participating in Epstein's sex-trafficking venture. 2. Banking Regulations Exist to Help Prevent Funding of Criminal Ventures. 178. The Federal Bank Secrecy Act ("BSA") requires financial institutions to have adequate anti-money laundering ("AML") policies and systems in place. New York state law requires f