Bank of America and the Bank of New York Mellon Corp. urged a Manhattan federal judge Thursday to toss lawsuits accusing them of enabling Jeffrey Epstein's sex trafficking enterprise and failing to timely report the late sex offender's suspicious transactions, saying "razor-thin allegations" don't connect the institutions to the crimes.

One of Epstein's survivors, identified as Jane Doe, alleged in nearly identical complaints last month that Bank of America and BNY provided financial support and the "veneer of institutional legitimacy" for Epstein and his co-conspirators' sex trafficking organization.

But both banks Wednesday moved to dismiss the litigation, arguing Doe is trying to hold them liable for Epstein's "abhorrent crimes" without actually providing plausible allegations that the financial institutions provided anything other than routine services to the late financier, who died by apparent suicide in his jail cell awaiting trial in 2019.

"The vast majority of the allegations in the complaint are generic assertions that are (aside from the defendant's name) word-for-word identical to a complaint that the same lawyers filed against an entirely different bank on the same day they filed this case," the BNY motion states, noting that there are only four paragraphs that contain allegations unique to BNY, "none of which alleges that Epstein ever opened or held accounts at BNY or was otherwise a customer of BNY."

"These razor-thin allegations fail to state a claim, and the complaint should be dismissed in its entirety," it states.

Doe alleges that BNY violated the Trafficking Victims Protection Act by knowingly participating in Epstein's sex trafficking scheme, but her suit doesn't allege that the bank provided any services to Epstein, much less the nonroutine kind needed to establish an inference of conduct to further sex trafficking, according to the motion.

Nor does the complaint "plausibly allege that BNY knew or should have known about any participation in sex trafficking, because there is not a single allegation of warning signs or red flags that would have been available to BNY in connection with any alleged Epstein-related transactions," the bank said.

The complaint also fails to allege that BNY received anything of value related to Epstein, let alone anything related to sex trafficking, and "outrageously asserts" the bank itself committed sex trafficking without providing any factual support, the motion states.

Bank of America, meanwhile, called the litigation "threadbare and meritless," arguing that the complaint "largely recycles boilerplate allegations" from prior lawsuits and public reporting.

And "when the court previously allowed some Epstein-related claims against banks to survive motions to dismiss, it did so largely based on those complaints' non-conclusory allegations of non-routine services, such as giving Epstein large quantities of cash, helping him structure cash withdrawals to elude suspicion, delaying reports for thousands of suspicious transactions totaling more than $1 billion, and permitting the use of a subsidiary's jet to transport young women," the bank said.

"No such allegations appear here," it continued. "The complaint alleges that Bank of America provided routine services to customers who at the time had no known connection to Epstein's sex trafficking. That is insufficient."

For instance, Doe fails to allege Bank of America was a participant in sex trafficking "because the transactions she references bore no indicia of the criminal purpose," and she doesn't offer any nonconclusory allegations that the bank knew or should have known she was being trafficked, the motion states.

What's more, her state-law negligence claims are time-barred, the bank said, noting that her latest possible injury happened in 2019, when Epstein died, and her suit comes six years after the last possible injury — "well outside the three-year statute-of-limitations window."

"Bank of America opposes trafficking in all its forms," the bank said. "But this suit attempts to radically expand liability for banks, holding them liable for providing ordinary banking services to individuals one or more steps removed from a trafficker — far beyond what the TVPRA allows."

Doe, who says she was abused by Epstein and forced to engage in sex work from 2011 through 2019, alleged the two banks failed to follow anti-money laundering requirements under the Federal Bank Secrecy Act, which provided "the underpinnings for Epstein to have ready and reliable access to financial resources to recruit, lure, coerce, and entice young women and girls to cause them to engage in commercial sex acts and other degradations."

The banks wanted to keep Epstein as a client because of his connections and referrals of other high-net-worth clients, according to the complaint. And Epstein could not have expanded his operation without "complicit" banks ignoring red flags, the suit alleges.

Doe wants to represent two classes of women "who were sexually abused or trafficked by Jeffrey Epstein or Epstein's co-conspirators" during the time when Bank of America and BNY maintained bank accounts for Epstein, his co-conspirators, related entities and other related accounts, according to the suits.

The suits assert claims of knowingly benefiting from, participating in and aiding a sex trafficking venture in violation of the Trafficking Victims Protection Act, obstructing enforcement of the TVPA, negligently failing to prevent physical harm, and negligently failing to exercise reasonable care as a banking institution providing nonroutine banking services.

"The claims in the lawsuit are meritless, and we will vigorously defend against it," a BNY spokesperson told Law360 Thursday.

Counsel for Doe and a representative for Bank of American declined to comment.

Doe's attorneys at Boies Schiller Flexner LLP in recent years have led similar lawsuits accusing Deutsche Bank and JPMorgan Chase & Co. of enabling Epstein's crimes.

Deutsche Bank agreed to pay $75 million to resolve proposed class claims on behalf of women and girls who were sexually abused or trafficked by Epstein or his associates from Aug. 19, 2013, to Aug. 10, 2019. The deal won preliminary approval in June 2023.

That same month, JPMorgan agreed to pay $290 million to resolve claims on behalf of Epstein's survivors. The deal was granted final approval in November 2023.

Doe is represented by David Boies and Sigrid S. McCawley of Boies Schiller Flexner LLP and Bradley J. Edwards and Brittany N. Henderson of Edwards Henderson.

Bank of America is represented by Charlotte H. Taylor, Bethany K. Biesenthal, Paula Quist, Shea F. Spreyer and Carol T. Li of Jones Day.

BNY is represented by Felicia H. Ellsworth, Boyd M. Johnson III, Christopher Bouchoux and Andres C. Salinas of WilmerHale.

The cases are Jane Doe v. Bank of America NA, case number 1:25-cv-08520, and Jane Doe v. The Bank of New York Mellon Corp., case number 1:25-cv-08525, both in the U.S. District Court for the Southern District of New York.