When Bank of America alerted financial regulators in 2020 to potentially suspicious payments from Leon Black, the billionaire investor, to Jeffrey Epstein, the disgraced financier, the bank was following a routine practice.

The bank filed two “suspicious activity reports,” or SARs, which are meant to alert law enforcement to potential criminal activities like money laundering, terrorism financing or sex trafficking. One was filed in February 2020 and the other eight months later, according to a congressional memorandum reviewed by The New York Times.

SARs are expected to be filed within 60 days of a bank spotting a questionable transaction.

But the warnings in this case, according to the congressional memo, were not filed until several years after the payments, totaling $170 million, had been made. By the time of the first filing, Mr. Epstein had already been dead for six months, after taking his own life in a Manhattan jail following his arrest on federal sex trafficking charges.

The delayed filings have led congressional investigators to question if Bank of America violated federal laws against money laundering. Also of concern to investigators is that the bank apparently processed the payments “without asking for information as to the nature of the transactions,” the memo said. The bank told regulators in its initial filing that the wire transfers had “no apparent economic, business or lawful purpose,” according to the memo.

The details in the congressional memo also illustrate a problem with the SARs system. Each year banks file millions of these confidential reports with regulators, but it is not uncommon for banks to file them long after the transactions have taken place. Banks may not act because they’re unaware of a reason to dig deeper into a transaction, or they may not want to cause trouble for a wealthy customer, money laundering experts say.

The memo, prepared by staff working for Senator Ron Wyden, the Oregon Democrat and chair of the Senate Finance Committee, recommended that Mr. Wyden ask the Treasury Department’s Financial Crimes Enforcement Network to investigate Bank of America’s conduct. The finance committee has been conducting its own investigation into the large payments from Mr. Black to Mr. Epstein for nearly two years.

A spokesman for Mr. Wyden said he was still considering the recommendations, but was likely to follow through on them.

The payments from Mr. Black to Mr. Epstein — made between 2012 and 2017 — have been a source of controversy since late 2020, when The New York Times reported that the business and personal ties between the two men were far greater than previously known. The dealings between the two men contributed to Mr. Black’s decision in early 2021 to step down as chief executive of Apollo Management, the private equity firm of which he was a co-founder.

Mr. Black, a Bank of America customer with a net worth of $13 billion, has insisted that the payments were for legitimate tax work and advice on art transactions. Dechert, a law firm hired by Apollo to review Mr. Black’s dealings with Mr. Epstein found that the work had saved Mr. Black nearly $2 billion in federal taxes.

The law firm said there was no evidence Mr. Black knew of Mr. Epstein’s predatory behavior. It found that he made $158 million in payments, and a $30 million loan to Mr. Epstein.

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