Ehhh, it can be (there used to be ads in the back of the Economist for this sort of thing). The hard part is getting correspondent relationships with bigger banks (i.e. a bank account for your bank).

The difficulty of that exercise is supposed to be directly proportional to the AML/KYC reputation of the jurisdiction granting the charter.

Exceptions abound, of course, and possession of incriminating video of a bank executive might make it a lot easier.

Very generally speaking, it costs about $5M to start a U.S. bank. Someone of Epstein's personal wealth, not to mention the assets under his control, would not have a problem starting a bank easily. His criminal record would have been an issue in the U.S., however, and any regulator worth their salt should have found it and denied the charter accordingly.

Kinda suggests Epstein somehow had an ability to evade the normal rules and laws of society, doesn't it?