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Deutsche Bank also provided funds through wire transfers and by mail. 
159. Deutsche Bank also aided and abetted Epstein's sex-trafficking venture 
by, among other things, providing the financial underpinnings for the venture. 
160. Deutsche Bank also conspired with Epstein and others to violate 18 
U.S.C. § 1591, by, among other things, adopting the purpose of providing victims 
for Epstein to sexually abuse. 
161. Deutsche Bank enabled Epstein to have ready and reliable access to 
resources—including cash and a variety of bank accounts and other financial tools—
to recruit, entice, solicit, harbor, provide, obtain, and transport young women and 
girls to sexually abuse them and to cause them to engage in commercial sex acts. 
162. Deutsche Bank knowingly and intentionally benefited financially and 
in other ways from its participation in Epstein's sex-trafficking venture with 
knowledge, or with reckless disregard to the fact, that Epstein used means of force, 
threats of force, fraud, and coercion (and combinations thereof) to force young 
women and girls to be sexually abused and to engage in commercial sex acts. 
163. When considering whether to participate in the sex-trafficking venture, 
Deutsche Bank estimated that it would earn between $2,000,000 to $4,000,000 
annually from serving as Epstein's banker. 
Deutsche Bank knew that being 
Epstein's banker required joining in the purposes of the sex-trafficking venture and 
funding the venture. 
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164. As recounted more fully in the paragraphs that follow, Deutsche Bank 
did financially benefit by earning millions of dollars from its participation in the 
Epstein-sex-trafficking venture. The benefits that Deutsche Bank received came 
directly from its participation in the sex-trafficking venture and because of its 
participation in that venture. In other words, there was a causal relationship between 
Deutsche Bank's conduct furthering Epstein's sex-trafficking venture and its receipt 
of the financial benefits with actual (and constructive) knowledge of that causal 
relationship. 
165. Deutsche Bank knowingly and intentionally financed Epstein's illegal 
sex-trafficking venture. Deutsche Bank knew that if it did not finance Epstein's 
illegal sex-trafficking venture, then it would lose valuable Epstein-related accounts. 
Faced with the choice between profiting from Epstein's sex-trafficking venture or 
following the law, Deutsche Bank intentionally chose to profit. 
166. In violation of various banking laws and regulations, including various 
"Know Your Customer" and anti-money laundering laws, Deutsche Bank regularly 
authorized cash withdrawals and deposits for the Epstein sex-trafficking venture, as 
well as wire transfers, which allowed Epstein, his co-conspirators, and those they 
directed to conduct the business of the sex-trafficking venture. 
167. Deutsche Bank's knowing and intentional banking law violations 
allowed Epstein and his various corporations to stay "under the radar" and continue 
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the sex trafficking operation without close scrutiny or interference. 
168. By facilitating and financing Epstein's sexual abuse and commercial 
sex acts in interstate and foreign commerce, Deutsche Bank earned interest, 
commissions, fees, and other financial benefits directly from its connection with 
Epstein, Epstein-related entities, and others acting in concert with Epstein. Epstein 
provided those financial benefits to Deutsche Bank precisely because it was 
facilitating his sex-trafficking venture—and Deutsche Bank knew that was the 
reason that Epstein was providing them with those financial benefits. 
169. Deutsche Bank knowingly and intentionally benefited financially from 
Epstein's sexual abuse and sex-trafficking venture by obtaining customer accounts. 
Epstein and his co-conspirators even forced Jane Doe 1 to open an account at 
Deutsche Bank, which financially benefited Deutsche Bank and simultaneously 
created greater connection between Jane Doe 1 and the Epstein organization, making 
escape more difficult. 
170. Deutsche Bank knowingly and intentionally benefited financially from 
Epstein's sexual abuse and sex-trafficking venture by profiting from the funds that 
Epstein, his co-conspirators, and his wealthy associates deposited with Deutsche 
Bank. 
171. For example, Deutsche Bank profited financially from funds deposited 
by or controlled by (among other Epstein-related entities): (1) Southern Trust 
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Company, Inc., (2) Southern Financial LLC, (3) The Butterfly Trust, (4) Global 
Markets Account, and (5) Gratitude America. 
172. Deutsche Bank benefited by receiving things of value from its 
participation in Epstein's sexual abuse and the Epstein sex-trafficking venture. 
Among the various things of value it received were: (1) connections with Epstein, 
his co-conspirators, and his wealthy friends and associates; (2) additional deposits 
from Epstein, his co-conspirators, and his wealthy friends and associates; (3) the 
ability to charge above-normal fees to Epstein because he was a "high risk, high 
reward" customer; and (4) the opportunity to earn financial benefits from the funds 
that had been deposited with it. Deutsche Bank knowingly received these things of 
value as a direct result of its participation in the Epstein sex-trafficking venture, 
which included actively concealing the illegality of it in order to keep the trafficking 
organization in business. 
173. Among the women and girls whose sex trafficking and sex abuse 
Deutsche Bank furthered were Jane Doe 1 and the Class Members, as each would 
not have been abused by this scheme but for Deutsche Bank's knowing venture with 
Epstein to provide the financial infrastructure to the sex-trafficking criminal 
enterprise. 
174. On July 20, 2020, the New York State Department of Financial Service 
(hereinafter "New York Banking Regulators") and Deutsche Bank agreed to a 
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Consent Order, which resolved the Department's investigation into Deutsche Bank's 
relationship with Epstein and Epstein-related entities. Deutsche Bank agreed to pay 
a penalty of $150 million to resolve the investigation regarding Epstein and two 
other customers. 
175. The New York Banking Regulators found, accurately, that Deutsche 
Bank conducted business regarding Epstein in an unsafe and unsound manner, in 
violation of New York Banking Law § 44. 
176. The New York Banking Regulators found, accurately, that Deutsche 
Bank failed to maintain an effective and compliant anti-money laundering program, 
in violation of 3 NYCRR § 116.2. 
177. While this complaint refers to facts found by the New York Banking 
Regulators, the allegations made in this complaint extend beyond those facts. In 
particular, the regulators did not address issues surrounding Deutsche Bank's 
criminal liability for participating in Epstein's sex trafficking venture. 
This 
complaint sweeps more broadly and accurately alleges that Deutsche Bank engaged 
in intentional criminal behavior in participating in Epstein's sex-trafficking venture. 
2. Banking Regulations Exist to Help Prevent Funding of Criminal 
Ventures. 
178. The Federal Bank Secrecy Act ("BSA") requires financial institutions 
to have adequate anti-money laundering ("AML") policies and systems in place. 
New York state law requires financial institutions to devise and implement systems 
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reasonably designed to identify and report suspicious activity and block transactions 
prohibited by law. 
179. All regulated institutions are expected to configure systems based on 
their unique risk factors, incorporating parameters such as institution size, presence 
in high-risk jurisdictions, and the specific lines of business involved, and the 
institutions have an affirmative duty to ensure that their systems run effectively. 
180. In addition to having effective AML controls in place, it is also 
necessary for financial institutions to monitor their customers for the purpose of 
preventing their customers from facilitating criminal activity using the institutions' 
facilities. 
181. As part of preventing criminal activity, Know Your Customer ("KYC") 
and customer due diligence are critically important, and financial institutions must 
collect customer information at the time of establishing new relationships with 
clients, including as necessary to assess the risks associated with the client. To 
properly consider these risks, financial institutions must consider relevant factors 
such as the nature of the client's business, the purpose of the client's accounts, and 
the nature and duration of the relationship. 
182. Financial institutions must also conduct KYC reviews for each client 
relationship at intervals commensurate to the AML risks posed by the client, 
including reviewing account activity to determine whether such activity fits with 
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what would have been expected given the nature of the account. Each client's AML 
risk should also be re-assessed if material new information or unexpected account 
activity is identified. 
183. Financial institutions must also file reports with federal authorities of 
suspicious activities by their customers, including suspicious cash activities, known 
as Suspicious Activity Reports ("SARs"). 
184. Financial institutions must also establish criteria for determining when 
a client relationship poses too high of a risk and therefore must be terminated. A 
financial institution may facilitate illegal activity—and be liable under applicable 
laws—if it maintains such a relationship despite repeated indications of facilitation 
of improper transactions. 
3. Deutsche Bank's Knowledge about the Epstein Venture. 
185. The New York Banking Regulators determined, accurately, that 
Deutsche Bank failed in various respects to meet its Know Your Customer and other 
obligations fully with respect to its relationship with Jeffrey Epstein and entities 
related to Epstein. The motive for those failures was simple: the bank was making 
millions of dollars for its knowing participation in and concealment of Epstein's 
criminal organization. 
186. In around 2013, Deutsche Bank was aware that Epstein was a wealthy 
man with hundreds of millions of dollars in assets and an extensive network of 
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friends and connections that included prominent financial institutions, politicians, 
royalty, and billionaires. 
187. In around 2013, Deutsche Bank was aware that Epstein also had a well-
publicized reputation related to the sexual trafficking and sexual abuse of young 
women. 
188. Allegations against Epstein began appearing in the press as early as 
2005, with the accusation that he paid a 14-year-old girl for a "massage." 
189. That year, the Palm Beach Police Department in Florida began an 
investigation into allegations against Epstein related to his sexual abuse in Palm 
Beach. The investigation quickly uncovered dozens of other Epstein sex-abuse 
victims. The investigation also identified the Epstein sex-trafficking venture, which 
included a number of individuals who were responsible for recruiting young women 
to come to Epstein's Palm Beach mansion to give "massages" or otherwise 
furthering his abuse. 
190. In 2006, the Palm Beach State Attorney handling the case referred the 
matter to the Federal Bureau of Investigation, which subsequently opened its own 
investigation and interviewed potential witnesses and victims. 
191. In September 2007, Epstein agreed to plead guilty to two felony sex 
offenses in Florida state court, in exchange for a federal Non-Prosecution Agreement 
("NPA") providing him and his co-conspirators (including Lesley Groff, Sarah 
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Kellen, Adriana Ross, and Nadia Marcinkova) with immunity from federal 
prosecution for extensive federal sex-trafficking charges in Florida. The deal 
included incarceration and for Epstein to register as a "Sex Offender." 
192. In the summer of 2008, Epstein's NPA with the U.S. Department of 
Justice was made public when it was unsealed in connection with a challenge 
brought to the NPA by two of his victims. The agreement, among other things, 
outlined charges that could have resulted from the investigation, including that 
Epstein conspired to use a facility or means of interstate commerce to induce minors 
to engage in prostitution, to engage in illicit sexual conduct with minors, conspiring 
with others to do the same, and trafficking minors. That agreement also noted that 
the United States had compiled "a list of individuals whom it [had] identified as 
victims," and that Epstein would pay for legal representation for these alleged 
victims. 
193. Court proceedings involving the challenge to Epstein's NPA continued 
between 2008 and 2013 (and beyond) and attracted extensive media attention. 
194. Indeed, between around 2006 and 2013, press reports outlined the 
allegations underlying the NPA and to varying degrees detailed the involvement of 
Epstein's alleged co-conspirators, including Lesley Groff, Sarah Kellen, and Nadia 
Marcinkova. 
195. The names of these women and other alleged co-conspirators were 
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publicly known by 2013. 
196. Additionally, press reports during this time noted allegations that 
Epstein was involved with Eastern European women in particular and that a 
modeling agency he helped fund along with a known sexual abuser Jean Luc Brunel 
brought "young girls ... often from Eastern Europe" to the U.S. on Epstein's private 
jets. 
197. By the time Deutsche Bank onboarded Epstein and during the 
relationship between the bank and Epstein and his many related entities, hundreds 
of pages of police reports, countless news articles, dozens of public civil lawsuits 
and corresponding settlements, Epstein's sexual offender registration, numerous 
depositions, and other overwhelming evidence of Epstein's sexual abuse was public 
and known to Deutsche Bank. 
198. Deutsche Bank was aware of the foregoing information and more about 
Epstein's sex abuse and sex trafficking activities by around 2013, and also of the 
fact that JP Morgan was terminating its relationship with Epstein when it considered 
whether to begin a banking relationship with Epstein. 
199. Deutsche Bank took in Epstein as a client because it knew this was an 
opportunity to take in a wealthy criminal that no other bank would take and make 
significant profits providing the infrastructure Epstein's sex trafficking operation 
desperately needed to continue. 
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4. Deutsche Bank Agrees to Become Epstein's Banker in 2013. 
200. In 2013, Epstein, who had been banking with one of Deutsche Bank's 
competitors, .n) Morgan, began the process of moving his assets to Deutsche Bank. 
201. The relationship between Deutsche Bank and Epstein came about 
through a Deutsche Bank relationship manager, Paul Morris, who had left JP Morgan 
bank ("JP Morgan") to join the Bank's private wealth department. At JP Morgan, 
Morris had been a member of the team servicing Epstein's accounts and he was 
aware of JP Morgan's role of facilitating Epstein's sex-trafficking venture and 
conspiracy. 
202. Paul Morris joined Deutsche Bank in November 2012, bringing with 
him the knowledge he had acquired at JP Morgan about Epstein's sex-trafficking 
venture and conspiracy. Soon after joining Deutsche Bank, Morris suggested to 
senior management that Epstein was a potential client who could generate millions 
of dollars of revenue as well as leads for other lucrative clients to Deutsche Bank. 
Morris and Epstein began discussions in the spring of 2013 about a potential 
relationship between Deutsche Bank and Epstein. 
203. In April of 2013, in preparation for establishing Deutsche Bank's 
relationship with Epstein, a junior relationship coordinator on the Epstein account 
(herein, "Relationship Coordinator-1") prepared a memorandum for Paul Morris to 
send to Deutsche Bank's then co-head of the Wealth Management Americas Group, 
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Charles Packard, and Patrick Harris, the Chief Operating Officer of Wealth 
Management Americas. 
204. Among other things, the memorandum contained information 
concerning Epstein's previous plea deal and prison sentence for sex-trafficking 
related crimes. In particular, the memorandum stated that "Epstein was charged with 
soliciting an underage prostitution [sic] in 2007," that "[h]e served 13 months out of 
his 18-month sentence," and that "[h]e was accused of paying young woman [sic] 
for massages in his Florida home." It also highlighted that Epstein was involved in 
17 out-of-court civil sex abuse settlements related to his 2007 conviction. 
205. In the email to Charles Packard and Patrick Harris attaching the 
memorandum, Paul Moths noted how lucrative becoming Epstein's banker could 
be, stating "[e]stimated flows of $100-300 [million] overtime [sic] (possibly more) 
w/ revenue of $2-4 million annually over time." In the same email, Moths proposed 
that all Epstein-related accounts be for "entities" affiliated with Epstein, "not 
personal accounts." 
206. On May 5, 2013, Charles Packard sent an email (hereinafter, the 
"Approval Email") to Moths, which read "spoke with [the Head of AML 
Compliance for Deutsche Bank Americas and the then-General Counsel for 
Deutsche Bank Americas, who at that time served as chair of the Bank's Americas 
Reputational Risk Committee ("ARRC")]. 
Neither suggest [that the Epstein 
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relationship] requires rep risk and we can move ahead so long as nothing further is 
identified through KYC and AML client adoptions." The ARRC did not meet in 
connection with the initial onboarding of Epstein. 
207. "Rep risk" as referenced in the Approval Email referred to a review by 
the relevant regional reputational risk committee. Deutsche Bank's policies and 
procedures provided that, should a Deutsche Bank business or compliance unit 
identify a client that they believe could pose a reputational risk to the Bank, it must 
escalate that client for review by the attendant reputational risk committee. In the 
case of the onboarding of the Epstein relationship, this was the ARRC. 
208. At the time, Deutsche Bank was aggressively expanding its U.S. wealth 
management business under its new co-chief executive, Anshu Jain, and was 
courting wealthy clients shunned by other banks. Indeed, attractive earnings 
multiples had driven strong investment from Deutsche Bank into asset and wealth 
management, as they consumed less capital than the investment banking business. 
Deutsche Bank officials have repeatedly called the Bank's private banking wealth 
management business in the Americas as a "key geographic region." Karimi et al. 
v. Deutsche Bank Aktiengesellschaft et at, Case No. 2:20-cv-08978-ES-JRA (case 
later transferred to this Court, Case No. 1:22-cv-02854-JSR) ("Karim?), Second 
Amended Complaint (Dkt. 37) at ¶ 84 (D.N.J. Mar. 1, 2021). 
209. According to confidential witnesses in another case before this Court, 
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no formal KYC investigation was ever ultimately undertaken for Epstein. See 
Karimi, Opinion and Order (Dkt. 86) at 9 (S.D.N.Y. June 13, 2022). Deutsche Bank 
intentionally avoided conducting such an investigation because it knew what the 
investigation would reveal, and that it would not be able to serve Epstein after such 
an investigation based on his well-documented and publicized history of sex 
trafficking. 
210. The relationship between Deutsche Bank and Epstein officially began 
on August 19, 2013, when the Bank opened brokerage accounts for Southern Trust 
Company Inc., a self-described "database company and services" founded in the 
U.S. Virgin Islands in 2011, and Southern Financial LLC, a wholly owned subsidiary 
of Southern Trust Company Inc. According to the KYC record, the purposes of the 
brokerage accounts were to "hold marketable securities and cash" and "to invest 
long term [sic] with the bank," respectively. Over the course of the relationship, 
Epstein, his related entities, and associates would eventually open and fund more 
than 40 accounts at Deutsche Bank, with more than $110 million in just one of the 
accounts. See Karimi, Dkt. 37 at ¶ 96. 
5. Epstein Uses Deutsche Bank Accounts for the Sex-Trafficking 
Venture. 
211. From the time of Epstein's onboarding, the relationship was classified 
by Deutsche Bank as "high-risk" and therefore subject to enhanced due diligence 
requirements. Although the Bank did not initially classify Epstein as a politically 
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exposed person ("PEP"), the Bank did designate him an "Honorary PEP" because of 
his connections to prominent political figures. The high-risk classification and 
informal designation as an Honorary PEP should have resulted in enhanced 
transaction monitoring of activity within Epstein's accounts. However, and as 
discussed below, this required monitoring scrutiny was not followed. The reason that 
Deutsche Bank did not give this scrutiny to Epstein is that it knew that doing so 
would more fully reveal Deutsche Bank's participation in and responsibility for 
Epstein's sex-trafficking venture. 
212. As early as November 1, 2013, Epstein and other co-conspirators in his 
sex-trafficking venture began using Deutsche Bank accounts to make wire transfers 
of money to facilitate Epstein's sex abuse and his sex-trafficking venture. Over the 
course of the relationship, Epstein and his representatives used Deutsche Bank 
accounts to send dozens of wires, directly and indirectly, including at least 18 wires 
in the amount of $10,000 or more to then known co-conspirators in the sex-
trafficking venture, including Lesley Groff, Sarah Kellen, and Nadia Marcinkova—
individuals who were listed as Epstein's co-conspirators in his Non-Prosecution 
Agreement with the U.S. Attorney's Office in Florida. 
213. Deutsche Bank was aware that the recipients of some of these wire 
transfers described in the previous paragraph were to Epstein's co-conspirators, as 
described further below. Deutsche Bank was aware that its wire transfers were in 
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furtherance of Epstein's sexual abuse and the Epstein sex-trafficking venture. 
214. On January 24, 2014, Deutsche Bank opened checking and money 
market accounts for an Epstein-related trust named "The Butterfly Trust." The 
Butterfly Trust included a number of beneficiaries, including, among others, Lesley 
Groff, Sarah Kellen, and Nadia Marcinkova, and a number of women with Eastern 
European surnames. When Deutsche Bank personnel asked Epstein and Epstein's 
representatives about his relationship with the beneficiaries, Epstein represented that 
they were employees or friends. Deutsche Bank's KYC records state that the 
purpose of the money market account was "to pay all expenses/disbursements 
related to the trust [such as] taxes, trust fee [sic], etc." 
215. The Butterfly Trust accounts were, like the overall Epstein relationship 
itself, approved for onboarding based on the earlier Approval Email from Charles 
Packard, despite obvious reputational and possible financial crime risks. 
Specifically, the beneficiaries of the Butterfly Trust included, among others, known 
criminal co-conspirators Lesley Groff, Sarah Kellen, and Nadia Marcinkova. The 
existence of co-conspirators as beneficiaries of the trust further established Deutsche 
Bank's actual and constructive knowledge that payments through the Trust would 
be used to further or coverup criminal activity and to endanger more young women 
and girls as victims of Epstein's sexual abuse and the Epstein sex-trafficking 
venture. 
In addition, Paul Morris had actual and constructive knowledge of 
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Epstein's sex-trafficking venture because of his previous time at JP Morgan. 
216. At the time of onboarding of the Butterfly Trust accounts, Deutsche 
Bank was aware that the Trust's beneficiaries were co-conspirators of Epstein's prior 
sex trafficking-related offenses. In October 2013, a compliance officer performed 
background checks on the beneficiaries of the trust and flagged for Paul Morris that 
one of the beneficiaries, Sarah Kellen, had been alleged to be one of Epstein's co-
conspirators. In reply, Morris confirmed that Kellen "was accused as a co-
conspirator in a case but was never brought to trial nor ever convicted. The account 
for which she will be associated is a trust account which names her as a beneficiary." 
The alert was cleared citing the Approval Email from Paul Morris. Morris had 
knowledge that Kellen was part of the Epstein sex-trafficking venture. 
217. While Epstein held accounts at Deutsche Bank, he used the Butterfly 
Trust account and various other accounts to send over 120 wires totaling $2.65 
million to beneficiaries of the Butterfly Trust. These transfers furthered his sex 
abuse and the sex-trafficking venture, including funds paying directly for coercive 
and commercial sex acts, funds paid to professionals for carrying out illegal acts for 
the operation of the sex-trafficking venture, and paying funds to others for 
committing crimes necessary to continue the operation of the sex trafficking venture. 
218. Epstein used Deutsche Bank accounts to pay for coerced commercial 
sex acts by Jane Doe 1, an individual Morris and others at Deutsche Bank knew was 
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a victim of Epstein's illegal operation. 
219. Given Deutsche Bank's knowledge about Epstein's past sex trafficking, 
its continuation of its financial relationship with Epstein after January 24, 2014 (and 
earlier) was, at a minimum, in reckless disregard of the fact that Epstein was using 
means of force, threats of force, fraud, coercion (and a combination of such means) 
to cause and coerce Epstein's victims to engage in commercial sex acts. 
220. By way of another example of the flagrant nature of Epstein's coercive 
sex-trafficking operation, in around 2013 certain of Epstein's foreign victims (who 
essentially lived with Epstein as commercial sex slaves) began having immigration 
problems and risked the possibility of deportation. Epstein's solution was to force 
certain of his American victims to enter into same-sex marriages with his foreign 
victims in order to prevent deportation and to exercise even greater control over all 
of the victims he caused to many one another. 
221. One way in which Epstein obtained victims to sexually abuse was by 
using sham marriages to keep control over select victims and keep them in the 
country. Epstein was paying fees from his Deutsche Bank account to a particular 
immigration attorney to coach the women who did not want to participate on what 
to say. Epstein also had his personal attorney — the same one that was corresponding 
with Deutsche Bank to coach him on circumventing reporting requirements in 
violation of federal structuring laws — meeting with the immigration attorney and 
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advising the women and signing related checks. 
222. Epstein even arranged for Deutsche Bank to open accounts in the 
names of certain of his victims. In doing all this, Epstein needed to know, with 
absolute certainty, that his bank would not report this highly suspicious and 
obviously illegal activity. Even though his relationship with Deutsche Bank was 
brand new, he knew the bank would assist him in this multi-layered criminal aspect 
of his sexually abusive international operation. And the reason Epstein knew this is 
that Deutsche Bank had, at a minimum, tacitly agreed to participate in his sex-
trafficking venture and was well aware that Epstein was a sex trafficker in need of a 
bank to aid in his illegal and abusive venture. 
223. With the marriages, like any other aspect of their lives under the rule of 
Epstein, the abuse victims were given no choice about whether to marry one another. 
224. Epstein demanded that they comply, and the "professionals" closest to 
Epstein choreographed the entire arrangement, from hiring and paying the crooked 
immigration attorney to falsifying records, to facilitating wire transfers, to 
establishing a bank account at Deutsche Bank. 
225. The sham marriage scheme, which was designed solely to perpetrate 
continued sexual abuse and trafficking through immigration and marriage fraud, was 
just another example of Epstein's brazen criminality that he could never have pulled 
off without a complicit bank protecting him. 
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226. Epstein used Deutsche Bank for all matters relating to his criminal sex-
trafficking enterprise because he knew that Deutsche Bank had agreed to disregard 
the fact that Epstein was using the account as part of his sex-trafficking venture. 
227. Deutsche Bank financially benefited from the accounts that Epstein 
used for his sex-trafficking operation, including the accounts for his many related 
entities, the personal accounts for his longtime attorney, and the accounts for some 
of his victims. 
228. Deutsche Bank, by providing the financial infrastructure to Epstein's 
illegal operation, was also able to justify charging Epstein higher. 
229. In addition to actual knowledge that it was facilitating the Epstein sex-
trafficking venture, Deutsche Bank benefited financially by participating in a 
venture that it should have known had engaged in coercive sex trafficking in 
violation of 18 U.S.C. § 1591(a). 
6. ARRC's Consideration of the Epstein Relationship 
230. Deutsche Bank's awareness that it was facilitating Epstein's sex-
trafficking venture continued to grow after January 24, 2014. 
231. In 2014 and into 2015, Deutsche Bank's Anti-Financial Crime 
department alerted Deutsche Bank's senior management to issues concerning 
Epstein's sex trafficking. Deutsche Bank's senior management chose to ignore 
Epstein's coercion of his victims because Deutsche Bank was profiting handsomely 
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