Leon Black:
The money, the family office, and the records that followed.

Leon Black co-founded Apollo Global Management and became one of the best-known figures in American private equity. According to the Dechert report later filed with the Securities and Exchange Commission, he met Jeffrey Epstein through a mutual acquaintance in the mid-1990s and developed a personal relationship long before retaining him professionally. In 1997, Epstein became an initial director of the Black Family Foundation, whose activities included philanthropic support for scientific and academic institutions. Dechert recorded that Epstein resigned from the foundation board in 2007, although some later tax filings continued listing him because his departure had not been reflected. The dates are important because they establish a long-term association and a governance-document discrepancy without establishing that a post-2007 listing represented continued board service. S01

Black maintained contact after Epstein pleaded guilty in Florida in 2008 to offenses that included procuring a person under eighteen for prostitution. Dechert reported that Black knew of those convictions but accepted Epstein’s characterization of the circumstances and considered it appropriate to preserve the relationship. The report attributed that decision to Black’s stated understanding of the case and his belief in allowing people a second chance. The relevant editorial question is how a continuing professional association with a known convicted offender came to be treated as acceptable within an exceptionally wealthy family office, and what documentary records show about the advice Epstein provided once the professional payments began. S01

Black established his family office in 2008, before the professional engagement with Epstein. It grew into the Elysium structure and involved employed advisers, outside counsel and accounting specialists. The official Dechert account describes Epstein working closely with the office from late 2012, reviewing estate and tax planning, advising on staff and operations, and pressing employees to submit major issues to him for comment. Witnesses considered some of his input useful while describing aspects of his management style as corrosive. In Dechert’s review, other lawyers and specialists continued to examine the substantive proposals, and the professional agreements did not grant Epstein formal fiduciary authority to bind Black. The distinction between practical influence and legal power should be visible throughout the exhibit because it determines what the current record can fairly attribute to Epstein personally. S01

Among the estate-planning issues Dechert highlighted were a 2006 grantor-retained annuity trust that advisers believed might otherwise produce substantial future estate-tax exposure, a later step-up-basis project whose intellectual origin became disputed, and work addressing tax compliance and artwork, aircraft and yacht matters. Black and several advisers believed Epstein delivered very large value in tax and estate advice, in some estimates exceeding $1 billion, while the review itself recorded disagreements over individual ideas and their valuation. Those claimed savings are assessments by the people Dechert interviewed, not the product of an independently published IRS determination. The 2016-2018 dispute over who originated the step-up-basis concept later became central to the breakdown of the paid relationship. S01

The released five-page document EFTA00301563 through EFTA00301567 reveals another proposed layer of legal protection. Its draft language places Epstein and Southern Trust Company in a consulting arrangement with Black family members, identifies Leon Black as their representative, and describes Epstein's work as assisting Carlyn McCaffrey and McDermott Will & Emery in the family's legal representation. It contemplates broad indemnification for Epstein while disclaiming authority to bind family members, fiduciary obligations, warranties and investment-adviser status, and it proposes confidentiality for communications and work papers. The recovered document contains blank dating and signature fields; whether any comparable provisions were ever executed remains an unresolved question rather than a conclusion about what obligations legally existed. S23

A March 2015 internal authority register identifies the actual decision makers across Black family companies. BV70 LLC listed Leon Black as a member, Debra Black as manager and president, and Eileen Alexanderson among those with delegated banking powers. The register separately describes Black Family Partners LP, Elysium Management LLC and Friends Ventures LLC, preventing the false inference that similarly controlled companies had identical legal authority or signed every transaction personally. In a separate April 2013 estate-planning memorandum, Ada Clapp copied Epstein on a summary of Black's 1997 revocable trust and attributed the legal instruments to lawyers at McDermott Will & Emery. Receipt of that legal summary does not mean Epstein originally drafted the will. S34 S37

Dechert calculated that Black paid Epstein-affiliated companies $158 million in compensation for services provided between 2012 and 2017. Its annual treatment was $50 million in 2013, $70 million in 2014, $30 million in 2015, no professional-service payment in 2016, and $8 million in 2017. The initial February 2013 agreement was signed; later proposed arrangements survive in several materially different drafts, and the disputed installment schedules must not be presented as one fully executed contract. The SEC-hosted report established the fee category as the committee’s reconstructed account of the parties’ professional relationship. S01

Senate Finance investigators subsequently published a broader approximately $169.8 million population of Black-related wire transfers to Epstein-related accounts, comprising the $158 million fee-year amounts, a $5.5 million 2012 item and an otherwise unexplained $6.3 million 2016 aggregate. The figures cannot be added as though they were separate populations of payments. The standing forensic register identifies the $5.5 million as an asset purchase while retaining the economic classification of the $6.3 million as unresolved. Its original wire-level sender, beneficiary, invoice and purpose remain acquisition targets. A record of 2016 money reaching an Epstein-related account does not, by itself, establish that Dechert’s $0 services classification for that year was false, because the payment might belong to a different category. S02 S09

The money trail extends to transactions that the professional-fee reconstruction does not subsume. Dechert described separate 2017 art-related loans totaling $30.5 million from a Black-controlled entity to an Epstein-controlled entity, with $10 million repaid and $20.5 million of principal still outstanding as described in the report. Dechert also recognized a $10 million contribution to Epstein-affiliated Gratitude America in October 2015. The report discusses a separate earlier $5 million acknowledgement but says that bank confirmation was lacking. The exhibit will therefore identify a confirmed $10 million charitable transfer, retain the purported $5 million as unconfirmed, and keep loans separate from advisory fees. The sender entity appearing on a particular transaction must be established from its contemporaneous bank instrument rather than assuming that the person whose wealth ultimately supported the payment initiated each wire directly. S01 S03

An additional valuation document places separate and important figures in the family-office record without establishing additional money paid to Epstein. In an October 16, 2015 appraisal, Empire Valuation Consultants estimated the fair market value of a 7.1266 percent interest in Black Family Partners LP at $128,076,087 as of July 24, 2015, in a restricted-use report prepared for attorney Alan Halperin of Paul, Weiss for an estate-planning GRAT annuity. Another Empire document, explicitly stamped draft and dated December 3, 2015, modeled the present value of a tax-receivable benefit available to Black Family Partners and rounded its restricted fair-market-value estimate to $137 million. These were appraisal estimates for different economic interests, not verified cash receipts, payments to Epstein, confirmed tax savings or additions to the $158 million fee population. S24 S25

A released FBI transaction exhibit provides the next level of precision on an earlier unresolved charity transfer. In Exhibit A, the October 14, 2015 $10 million movement to Gratitude America is listed as a payment by BV70 LLC, with Deutsche Bank production reference DB-SDNY-0004999. A separately published Senate bank communication used Black Family Partners LP in its discussion of that day's transactions, making it necessary to distinguish original sending accounts, proposed allocations and successive payment legs. The FBI compilation also contains transfers made by Edmond de Rothschild entities, which cannot be folded into Black's personal fee total simply because the pages carry a combined Black/Rothschild heading. Original bank instructions remain the necessary last step in authenticating the transfer-level classification. S32 S03

A December 2015 email supplies specific figures for another type of financial flow. A forwarded Gagosian Gallery table records Narrow Holdings payments of $23 million, $34.5 million and $28.75 million to the dealer, with corresponding payments of $21.16 million, $31.74 million and $26.45 million onward to Maya Picasso. Those amounts total $86.25 million in and $79.35 million onward, a $6.9 million difference representing exactly eight percent of the amounts entering the gallery. The sender questioned that eight percent result against an account of commissions split six-and-a-half and three-and-a-half percent, suggesting missing contract or allocation details. The documents do not establish that any intermediary kept money unlawfully or that Epstein was the ultimate beneficiary, and these 2015 art transactions are not additions to his advisory fees or the separate 2017 loans. S33

Newly examined documents expose a second art-business channel in which Epstein communicated about both personal payments and a sale involving Black-controlled entities. An OCCRP investigation, citing DOJ-released emails, reported that Black and related entities sent at least $2.5 million between 2011 and 2015 to art adviser Anastasiya Siroochenko's personal accounts. Accountants reportedly classified the transfers as gifts, and Siroochenko's Sublime Art LLC separately did business involving Black's collection. Those classifications raise questions about gift documentation, dealer invoices and who arranged transactions, but the reporting does not establish criminal wrongdoing or that Black directed the underlying accounting exchanges. Siroochenko expressly said her activities were legitimate and unrelated to criminal cases. The alleged personal transfers are neither Epstein's professional fees nor the Gagosian commission spread, and no aggregate should combine those categories without the original bank instruments. S40

The art commission trail contains an unusually precise before-and-after documentary comparison. A September 20, 2017 forwarded email, EFTA00688158, sent by Heather Gray at the Black family office to Sublime Art and then sent to Epstein for review, discusses a proposed Narrows Holdings commission agreement and sale of a Paul Klee painting. OCCRP's review describes an earlier proposed $7.8 million painting value and $1.8 million contingent commission; it does not establish payment. A September 18, 2018 Narrows Holdings invoice, EFTA00603470, identifies that Paul Klee work by title and instead lists a $6 million sale price payable to Narrows, with no sales tax because a resale certificate had been received. The invoice is stronger evidence of a billed sale than the 2017 preliminary discussion, but neither a final bank credit nor the final intermediary commission schedule has been recovered. Do not infer the earlier contemplated commission remained the final agreed amount or that Epstein personally received proceeds. S41 S42 S40

An agreement text in the publicly released EFTA00585511-EFTA00585526 family records a separate 2006 Black Family Trust accounting dispute. Its recitals state that the trustees had previously distributed $223,503,171 to Black, then recalculated trust income as $81,776,946 after determining they had included revenue from companies outside the operative class of “Relevant Companies.” The resulting excess is $141,726,225, an amount also raised in Senator Ron Wyden’s 2026 inquiry. The agreement text discusses potential releases, the cessation of future income payments and the treatment of claims by beneficiaries, while the presently recovered text does not conclusively establish execution of each proposed term or the downstream tax treatment. The figures establish the substance of a recorded accounting correction without proving that Epstein designed the original structure, personally caused the error, or facilitated a tax crime. S03 S10

An Epstein email dated December 21, 2016 describes plans to liquidate a trust called the J. Black Trust, to revisit gift-tax treatment and to address what Epstein referred to as sensitive accounts being discussed by a family-office executive. That is direct evidence of what Epstein proposed and how he characterized the accounts, but it is neither a completed liquidation instruction signed by a trustee nor evidence that the accounts were illegal. Independent repository analysis links this reference to a separate 2014 trust instrument, a matter requiring review of its original execution pages. The J. Black Trust must not be treated as the same entity as the 2006 Black Family Trust examined in the earlier $141.7 million distribution recalculation. S35 S36

Guzel Ganieva publicly accused Black of sustained sexual abuse and coercion, and her subsequent civil pleadings included allegations of rape. Black denied the accusations and described the relationship as consensual, while alleging that she sought financial concessions to conceal the relationship. The dispute generated a 2015 nondisclosure agreement and a series of payments. In separate litigation, Black said he paid $9,251,084 under the agreement between 2015 and 2021, while the New York appellate court referred to approximately $9 million in benefits. The difference in expression reflects different source categories and should not be represented as an unexplained new payment without examining the underlying terms. S04 S09

Records reproduced by Senate Finance contain messages between Epstein and attorney Brad Karp about surveillance and the movements of a woman whom committee staff believed to be Ganieva. The exchanges establish that Epstein sought and received information as the dispute continued; one reported message refers to what Black wanted investigators to establish. That is a contemporaneous third-party characterization, not a personally authenticated order from Black. Nardello has stated that Black’s counsel retained the investigative firm and that Nardello personnel did not communicate with Epstein. What remains to be determined from engagement and billing records is precisely who commissioned and paid for each investigative task and what authority governed the transfer of work product to Epstein. S03 S09

A July 2015 message separately attributed by Senate Finance to Epstein and Sergei Belyakov, then a Russian government official, discussed a woman from Moscow whom Epstein accused of blackmailing prominent New York businessmen and disclosed location information. The publicly extracted message itself did not name Black or Ganieva; the Senate connected it to Ganieva through other records. What can be directly established is a communication seeking suggestions from the recipient. Whether Belyakov replied, whether anyone acted on the information, or whether Black requested that communication remains unresolved. No protected current or detailed location information belongs in the public Atlas merely because a historical source included it. S03 S11

On January 16, 2025, the New York Appellate Division affirmed dismissal of Ganieva’s lawsuit on the basis that the NDA reached her claims and that her prolonged acceptance of benefits constituted ratification under the governing contract rules. On September 18, 2025, the Court of Appeals denied her motion for leave to appeal. In a separate case, Black sued Ganieva and her former lawyers for malicious prosecution; on March 6, 2025, the Appellate Division reversed the denial of a motion to dismiss, dismissed Black’s claim under the anti-SLAPP framework, and remanded the question of defendants’ attorney fees. The two appellate proceedings resolved separate legal theories. Neither appellate opinion conducted a trial establishing whether the underlying abuse allegations were true. S04 S05 S06

Cheri Pierson alleged that Black raped her at Epstein’s Manhattan townhouse in 2002. Black denied ever meeting her, and the existing litigation source ledger records discontinuance of her civil action with prejudice in 2024 without a trial on the allegation. Other released federal and Manhattan District Attorney records describe complaints involving Black, with important differences between firsthand interviews, a lawyer’s proffer, secondhand statements and hotline intake reports. A redacted record cannot safely be assigned to a named complainant on the basis of circumstantial similarities alone, and several accounts could overlap. S09

An anonymous federal plaintiff alleged that Black sexually assaulted her after Epstein trafficked her to him when she was sixteen. Black denied the accusation. In an April 23, 2026 decision, a federal judge found that the plaintiff’s journals contained three falsified sonograms and ordered sanctions against the plaintiff and former counsel Jeanne Christensen and Wigdor. The judge also found serious misrepresentations by counsel and failures to preserve potentially relevant social-media material, while distinguishing those failures from proven intent to deprive the defendant of evidence. The judge refused to terminate the case as a sanction and noted that the journal specifically describing the alleged Black encounter did not contain a falsified sonogram. Those precise boundaries matter because a finding of document falsification is a major adverse credibility development but does not establish that the underlying incident occurred or did not occur. S07

An August 24, 2026 district-court order followed appellate proceedings concerning unsealing and directed the former law firm to submit specified documents with redactions. The Atlas should report this as an unsealing directive, not as proof that every document was publicly filed or that the underlying civil action had reached final disposition. Black’s denials and the court’s explicit evidentiary findings need to appear within the same case-specific exhibit. The source register also records that the final formal disposition of the Manhattan District Attorney’s investigative work has not been recovered. S08 S09

Black entered a January 20, 2023 settlement with the government of the United States Virgin Islands for $62.5 million. Its terms allocated $15 million of that sum to a government-established program fund rather than adding $15 million on top of the negotiated amount, included broad releases within the agreement’s defined scope, preserved private individuals’ claims, and contained no admission of liability. The agreement recites that Epstein used some of Black’s money to help finance activity in the Virgin Islands, but that language alone does not establish Black’s knowledge of particular downstream transactions. This exhibit should show the operative release provisions and the specific exceptions, allowing readers to distinguish a negotiated settlement from a judicial finding. S12

Dechert reported that an Epstein-controlled company bought 263,257 Apollo shares in its 2011 initial public offering, while finding no investment by Epstein in any Apollo-managed fund and no Apollo retention of his professional services. The same memorandum acknowledged other tangential private-investment overlaps involving Apollo executives and recorded that Black had helped Epstein pursue introductions, while reporting no retention by other senior Apollo executives. A person’s direct stockholding, participation in a separately organized investment with executives, and investments in funds managed by an institution carry different financial and legal meanings. S01

Apollo’s August 2026 Form 10-Q disclosed two securities class actions:Feldman and Perez:subsequently consolidated, challenging among other things statements made in 2021 and 2022 about whether Apollo ever did business with Epstein. Apollo said it would defend the claims vigorously. The lawsuits establish what shareholders alleged and what Apollo disclosed to investors; they are not adjudicated findings that the representations were securities fraud. The documented IPO shareholding and the carefully qualified Dechert conclusion give readers a concrete basis for examining how the meaning of an institutional relationship was described. S13

The Dechert memorandum also described two early-2000s investments by Epstein’s Financial Trust Company in AP SHL Investors LLC and AP Technology Partners LLC. It described those vehicles as organized by certain Apollo executives to consider opportunities Apollo itself had not pursued, and said they were neither Apollo funds nor formal Apollo entities. Dechert further recorded that Financial Trust Company appeared to invest in Environmental Solutions World Wide alongside Black and members of his family in 2011. These are distinct and documented investment overlaps beyond the IPO shareholding, deserving separate sourced edges in the connections graph. They do not independently establish that Apollo’s managed funds received Epstein investments or that any participant knew of Epstein’s criminal conduct. S01

The 2026 Apollo-disclosure questions cannot be understood only by looking at the original Dechert conclusion. In a December 16, 2015 message, Leon Black's executive assistant Melanie Spinella told Epstein's aide Lesley Groff that Apollo co-founder Marc Rowan wanted to meet Epstein in early January and would rearrange his schedule if necessary. The message establishes a proposed meeting, not proof that one of the suggested dates became an actual appointment. Later publicly released correspondence concerning a March 4, 2016 exchange indicates Rowan forwarded Apollo internal tax-receivable-agreement calculation materials to Epstein. A February 2026 complaint letter from the American Federation of Teachers and the American Association of University Professors supplied that record, related correspondence, and a request for SEC review. Those documents raise a legitimate question about how Apollo's institutional disclosures described direct exchanges with Epstein, but neither the complaint letter nor a forwarded calculation proves that Apollo retained Epstein, that a suggested transaction closed, or that a court found a securities violation. S26 S27 S28

The original March 2, 2026 Feldman v. Apollo Global Management securities complaint names Apollo, Marc Rowan and Leon Black as defendants, alleging that corporate disclosures about Epstein's Apollo contacts were materially misleading. It alleges that Black remained a control person after leaving Apollo's chief executive role, citing a 7 percent common-stock holding at an April 2025 snapshot. Those are allegations pleaded in an investor lawsuit, not judicial findings that Black controlled Apollo's later communications or committed securities fraud. The complaint makes the relationship between post-2021 disclosures, Rowan's documentary exchanges with Epstein and Black's former executive role a concrete matter for litigation follow-up, rather than a claim the Atlas can resolve itself. S31 S13

Apollo's own February 18, 2026 letter provides a necessary reply to the documentary questions about Marc Rowan and other employees. Apollo rejected the claim that anyone other than Black had an Epstein business or personal relationship, while expressly acknowledging that Rowan and other staff had supplied information to Epstein in connection with Black's personal tax work. The company also said it had rejected proposed work with the other co-founders. This answer establishes how Apollo characterized the contacts, not a court's resolution of the later shareholder allegations, and belongs beside the corresponding Rowan scheduling messages and tax-calculation documents. S38

Institutional enforcement evidence adds context to Epstein's banking network without proving individual culpability. In July 2020, the New York State Department of Financial Services entered a consent order with Deutsche Bank assessing a $150 million civil penalty for failings in monitoring its Epstein relationship and separate correspondent-banking matters. The regulator found shortcomings in the bank's know-your-customer and enhanced monitoring procedures and documented concerns that should have been escalated despite Epstein's known conviction. This enforcement outcome does not establish that Black committed money laundering or even that each Black-related payment was suspicious; it identifies why the original compliance, wire and client-review records are indispensable. The regulator's penalty must never be added to Black's $62.5 million Virgin Islands settlement or Epstein's advisory fees. S43

Black gave a transcribed interview to the House Oversight Committee on June 26, 2026. Asked about payment provisions in the Ganieva agreement, he acknowledged that counsel’s summary sounded correct. He also acknowledged discussing the dispute with Epstein while denying that Epstein negotiated the NDA. In the subsequent subpoena dispute, the Committee alleged that Black failed to provide the requested deposition and complete NDA production, while his counsel objected to the breadth of demands and invoked privacy and relevance considerations. The House adopted H. Res. 1543 on September 16, 2026, finding Black in contempt of Congress over subpoena noncompliance and directing certification to the U.S. Attorney. The September 21, 2026 Congressional Record further confirms that the Speaker certified Black's refusal to comply with the two subpoenas to the United States Attorney for the District of Columbia under H. Res. 1543. Certification is a confirmed congressional referral step. A resulting indictment, prosecution or conviction is not established by these records. S14 S15 S44

A bank email is not a signed power of attorney. In April and May 2015, Brad Wechsler, Richard Joslin and Deutsche Bank personnel exchanged account-opening and transactional-authority documents concerning Black's investment arrangements. Wechsler described a JPMorgan individual account using his own power of attorney, said Apollo had addressed a compliance question, and discussed owner notification after certain transactions; he also described unfinished Deutsche documentation and a prospective amended foreign-account report concerning a British escrow account. Because the extracted correspondence reports intentions and administrative tasks, the central questions are which notarized authorities were actually executed, whose funds were traded, what transaction notices were delivered and whether the contemplated foreign-account amendment was filed. S16

A Deutsche Bank private-banking note separately describes Epstein as the intermediary who introduced Black to banker Paul Morris in connection with a proposed $500 million credit line, using the bank's description of Epstein as an estate and tax-planning attorney. This reveals the banking channel as an institutional relationship deserving its own proof of approval, drawdowns, referral fees and authorized access, although the bank's characterization of Epstein does not establish that he held a law license, owned the account, or received delegated authority over every related decision. S18

Another released instrument sharpens the unresolved 2017 loan story: a March 27 Southern Trust invoice requests $10 million from Black, while pages in the same released packet contain a $28.5 million Plan D promissory note payable to him at 1.01 percent interest and due in March 2018. The Dechert review elsewhere describes $30.5 million in art-related advances and a subsequent $10 million repayment, while also recording $8 million in 2017 professional-service compensation. Without the disbursement records, invoice settlement, ledger and any replacement-note history, these amounts cannot be added to each other, and the document packet does not establish why the loan was structured as it was. S17 S01

The philanthropic record reaches Harvard's Program for Evolutionary Dynamics. A December 2014 pledge in the Epstein files commits Black and his family foundation to a $5 million contribution benefiting Martin Nowak's program, with payments contemplated in two tranches. Other released correspondence identifies Richard Kahn as a conduit for coordinating the pledge with Epstein. Those documents establish the signed promise and routing communications, not proof that all promised funds were delivered, that the funds entered Epstein's personal accounts, or that Black endorsed the entirety of Epstein's scientific interests. S19

The distinction between what Epstein claimed and what can be proved matters again in a December 2015 email chain, where Epstein described work undertaken for Black and suggested that some things would remain unknown. A private 2016 letter draft also represents Epstein as having saved Black enormous sums in estate taxes, mentioning approximately $600 million and possible banking introductions. These are Epstein's untested claims and proposal language, respectively, so the response required is dated work product, knowledgeable witnesses and independent accounting rather than an assumption that the unknown tasks occurred or that the claimed savings were realized. S20 S21

Senator Ron Wyden's March 2026 letter had already posed 27 detailed questions about compensation, trusts, charitable routing, tax reporting, payments to women, the Virgin Islands settlement and surveillance. His June referral to the House continued to ask for invoices, signed agreements and evidence of actual services. Black's June House interview did not develop a transaction-level examination of these amounts before the parties reached an impasse over nondisclosure agreements and subsequent subpoenas, leaving a documented difference between questions officially raised and answers publicly established. This Atlas therefore publishes record-specific questions with a visible category for issues Congress has already raised and another for further documentary crosswalks. S03 S14 S22

The remaining highest-value documentary gaps are the line-by-line 2016 $6.3 million wires, original bank evidence resolving the 2015 sender and charitable recipient mechanics, the executed later-2013 service-agreement version if one exists, the trust signature and transaction schedules, private investigator instructions and payer records, specific transaction evidence for payments involving other women, the full formal Manhattan District Attorney closure record, and any verified follow-up to the 2015 Belyakov contact. These gaps provide precise questions for future releases and require no implication that missing documents were destroyed or intentionally suppressed. When an original remains unavailable, the exhibit should identify the closest recovered document, the responsible source of the statement and the evidence needed to upgrade the conclusion. S09

A separate banking lead published by independent researchers points to EFTA01359500, described as a Deutsche Bank roster that groups Leon D. Black and several Epstein-affiliated accounts under overlapping relationship officers. The account list and its dates require comparison with the original bank pages before adding any relationship as proven in the interactive graph; shared servicing personnel alone would not show knowledge of illegality. The Paradise Papers present a different, identity-sensitive lead: ICIJ lists an officer called "Black - Leon" as shareholder of Bermuda-incorporated Scientia Health Group Limited, but the entry does not itself establish that the officer is Leon D. Black, identify Epstein as involved, or suggest that foreign incorporation was unlawful. Both leads remain explicitly unconfirmed and excluded from the verified financial network pending original records and identification. S29 S30

On October 15, 2026, lawmakers introduced the Epstein Wall Street Records Act, a proposed law directed at disclosures and enforcement by federal banking and securities regulators. The Senate Banking Committee's announcement specifically called for opening supervisory records from the Federal Reserve, FDIC, OCC and SEC, investigating covered institutions and executives, and possible penalties or referrals where violations were established. The measure was introduced, not enacted; it neither names Black in the committee announcement nor constitutes any finding against him. It is important to this financial Atlas because bank-level verification of Black-related transactions remains incomplete and future regulator disclosures could supply the missing original compliance, supervisory and transaction materials. S39

The strongest outstanding documentary request regarding the Siroochenko–Narrows transactions is a joined set of bank receipts, final sale and consignment contracts, gift-tax filings, final invoice settlement, the buyer's remittance and any separate commission schedule. This is required to determine what fraction, if any, of the proposed $1.8 million commission or the $6 million Narrows invoice actually cleared. The 2017 proposal, 2018 invoice and OCCRP's account must remain clearly separated in the public record. S40 S41 S42