S. 4338 — Pedophile Financial Accountability Act

This section directs the Director of the Financial Crimes Enforcement Network (FinCEN) to investigate potential violations of the Bank Secrecy Act—requiring financial institutions to file suspicious activity reports (SARs) on transactions of $5,000 or more that a financial institution knows to be suspicious—by financial institutions and employees in handling transactions involving Jeffrey Epstein. The investigation must examine (1) failures to screen and timely file SARs; (2) delays and underreporting of SARs by institutions including JPMorgan Chase and Bank of America on large cash withdrawals, deposits, and wire transfers involving Epstein or his co-conspirators; (3) decisions to delay full reporting of Epstein's suspicious activity to the Treasury Department; (4) employee inquiries into the business purpose of Epstein's multimillion-dollar payments to clients including Leon Black and Les Wexner; (5) similar inquiries of wealthy individuals claiming payments to Epstein were for tax and estate planning; (6) use of USA PATRIOT Act section 314(b) information-sharing authorities for Epstein's transfers; and (7) senior executive conduct in allowing continued work with Epstein after exiting him as a client over money laundering concerns. Not later than 100 days after enactment, FinCEN must submit a report to Congress on the investigation, which may include information from Epstein-related SARs notwithstanding other laws. Where appropriate, FinCEN must refer to the Attorney General any employee potentially willfully violating the Bank Secrecy Act or other federal anti-money laundering laws.