EFTA00151495

NEW YORK STATE 
DEPARTMENT OF FINANCIAL SERVICES 
ONE STATE STREET 
NEW YORK, NEW YORK 10004 
x 
In the Matter of 
DEUTSCHE BANK AG, 
DEUTSCHE BANK AG NEW YORK BRANCH, and 
DEUTSCHE BANK TRUST COMPANY OF THE AMERICAS : 
--------------------------------------------- 
----------- 
-x 
CONSENT ORDER UNDER 
NEW YORK BANKING LAW 44 39 and 44 
The New York State Department of Financial Services (the "Department"), Deutsche 
Bank AG, Deutsche Bank AG New York Branch, and Deutsche Bank Trust Company of the 
Americas (collectively "Respondents," "Deutsche Bank," or the "Bank") are willing to resolve 
the matters described herein without further proceedings. 
WHEREAS, Deutsche Bank AG is a global financial institution headquartered in 
Frankfurt, Germany; 
WHEREAS, Deutsche Bank AG is licensed by the Department to operate a foreign bank 
branch in the State of New York, the Deutsche Bank AG New York Branch (the "New York 
Branch"), and also operates a trust company, Deutsche Bank Trust Company of the Americas 
("DBTCA"), which is likewise licensed and supervised by the Department; 
EFTA00151495

WHEREAS, the Department has been investigating various aspects of Deutsche Bank's 
operations, specifically, the Bank's relationship with Jeffrey Epstein and related entities and 
correspondent and dollar-clearing relationships with the Federal Bank of the Middle East Ltd. 
("FBME") and Danske Bank A/S ("Danske"); 
NOW THEREFORE, to resolve this matter without further proceedings pursuant to the 
Superintendent's authority under Sections 39 and 44 of the Banking Law, the Department finds 
as follows: 
THE DEPARTMENT'S FINDINGS FOLLOWING INVESTIGATION 
A. 
Introduction 
I. 
Global financial institutions act as a critical line of defense against illegal 
financial transactions in an ever changing and interconnected financial network. 
2. 
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 reasonably designed to identify 
and report suspicious activity and block transactions prohibited by law. 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. 
3. 
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. Further, Federal and 
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Departmental regulations require correspondent banks to conduct due diligence on, and monitor, 
non-U.S. respondent bank clients. 
4. 
As such, 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 should 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. For correspondent banking customers that are also foreign financial institutions, the 
due diligence should consider reasonably available information as to the customer's own AML 
record, the types of customers and markets served, and the AML regime in the client's home 
jurisdiction. 
5. 
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 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. 
6. 
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 
be liable under applicable laws if it maintains such a relationship despite repeated indications of 
facilitation of improper transactions. 
7. 
The Department has determined that Deutsche Bank failed in various respects to 
meet these obligations fully with respect to three different customer relationships: one direct 
customer relationship with Jeffrey Epstein and entities related to Mr. Epstein; and two dollar-
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clearing/correspondent banking relationships with foreign banks, FBME and Danske. Each will 
be addressed in turn. 
B. 
The Bank's Relationship with Jeffrey Epstein and Related Entities 
8. 
Jeffrey Epstein was a wealthy financier with hundreds of millions of dollars in 
assets and an extensive network of friends and connections that included prominent financial 
institutions, politicians, royalty, and billionaires. Deutsche Bank maintained a relationship with 
Mr. Epstein and related individuals and entities from August 2013 until December 2018. At that 
point the Bank decided to terminate this relationship following additional negative press related 
to Mr. Epstein's past criminal conduct. 
9. 
Mr. Epstein also had a well-publicized reputation related to the trafficking and 
abuse of young women. Allegations against him began appearing in the press as early as March 
2005 with the accusation that he paid a 14-year old girl for a "massage." 
10. 
That year, the Palm Beach (Florida) Police Department commenced an 
investigation into allegations against Mr. Epstein related to his activities in Palm Beach. The 
investigation quickly uncovered dozens of other alleged victims. In particular, the investigation 
identified a number of individuals who were responsible for recruiting young women to come to 
Mr. Epstein's house to give "massages" or otherwise furthering his abuse. Press reports state 
some of these women told victims they should inform Mr. Epstein that they were 18 years old 
and represented to victims that they would be paid for performing such "massages." 
II. 
According to press reports, in 2006 the State Attorney handling the case, after 
meeting privately with an attorney representing Mr. Epstein, referred the case to a state grand 
jury instead of charging Epstein and co-conspirators for crimes for which local police believed 
there was abundant evidence. As a result, the Palm Beach Police Chief publicly denounced the 
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State Attorney and referred the case to the Federal Bureau of Investigation, which subsequently 
opened its own investigation and interviewed potential witnesses and victims. 
12. 
In September 2007, Mr. Epstein agreed to plead guilty to two prostitution charges 
in state court, including the solicitation of a minor to engage in prostitution, in exchange for a 
deferred prosecution agreement providing him with immunity from extensive federal sex-
trafficking charges. The deal included an 18-month sentence and Mr. Epstein was also required 
to register as a sex offender upon his release. Mr. Epstein ultimately served only 13 months of 
his 18-month sentence in the Palm Beach County jail, and was allowed work release privileges 
that enabled him to leave jail six days a week for twelve hours a day. 
13. 
In 2009, Mr. Epstein's non-prosecution agreement with the U.S. Department of 
Justice was made public when it was unsealed in connection with one of several civil suits by his 
alleged victims. The agreement, among other things, outlines details from the investigation, 
including that Mr. Epstein may have 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 notes that the 
United States had compiled "a list of individuals whom it [had] identified as victims," and that 
Mr. Epstein would pay for legal representation for these alleged victims. 
14. 
Indeed, between 2005 and 2013, press reports outlined the allegations underlying 
the plea agreement and to varying degrees detailed the involvement of Mr. Epstein's alleged co-
conspirators, including three individuals hereinafter identified as CO-CONSPIRATOR-1, CO-
CONSPIRATOR-2 and CO-CONSPIRATOR-3. Some articles reported that CO-
CONSPIRATORS 1 and 2 had invoked their Fifth Amendment right against self-incrimination, 
and others reported that CO-CONSPIRATOR 3 had allegedly recruited underage girls to give 
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Mr. Epstein "massages." The names of these women and several other alleged co-conspirators 
were publicly known by 2013. 
15. 
Additionally, press reports during this time noted allegations that Mr. Epstein was 
involved with Eastern European women in particular and that a modeling agency he helped fund 
brought "young girls . . . often from Eastern Europe" to the U.S. on Mr. Epstein's private jets. 
Deutsche Bank Onboarded Epstein in 2013 
16. 
In early 2013, Mr. Epstein, who had been banking with one of Deutsche Bank's 
competitors (herein, "US BANK-11, began the process of moving his assets to Deutsche Bank. 
17. 
The relationship between Deutsche Bank and Mr. Epstein came about through a 
Deutsche Bank relationship manager (herein, "RELATIONSHIP MANAGER-1") who had left 
US BANK-1 to join the Bank's private wealth department. At US BANK-1, RELATIONSHIP 
MANAGER-1 had been a member of the team servicing Mr. Epstein's accounts. 
18. 
RELATIONSHIP MANAGER-1 joined Deutsche Bank in November 2012, and, 
soon after joining Deutsche Bank, suggested to senior management in Deutsche Bank that Mr. 
Epstein was a potential client who could generate millions of dollars of revenue as well as leads 
for other lucrative clients to the Bank. Although it is unclear who made the initial contact, 
RELATIONSHIP MANAGER-1 and Mr. Epstein began discussions in the spring of 2013 about 
a potential relationship between Deutsche Bank and Mr. Epstein. 
19. 
In April of 2013, in preparation for Mr. Epstein's onboarding, a junior 
relationship coordinator on the Epstein account (herein, "RELATIONSHIP COORDINATOR-
1") prepared a memorandum for RELATIONSHIP MANAGER-1 to send to the Bank's then Co-
Head of the Wealth Management Americas group (herein, "EXECUTIVE-1") and the Chief 
Operating Officer of Wealth Management Americas (herein, "EXECUTIVE-2"). 
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20. 
Among other things, the memorandum contained information concerning Mr. 
Epstein's previous plea deal and prison sentence. 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 highlights that Mr. Epstein was involved in 17 
out-of-court civil settlements related to his conduct in the 2007 conviction. 
21. 
In the email to EXECUTIVE-1 and EXECUTIVE-2 attaching the memorandum, 
RELATIONSHIP MANAGER-1 noted how lucrative the relationship 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, RELATIONSHIP MANAGER-1 proposed 
that all Epstein-related accounts be for "entities" affiliated with Mr. Epstein, "not personal 
accounts." 
22. 
On May 5, 2013, EXECUTIVE-1 sent an email (hereinafter, the "Approval 
Email") to RELATIONSHIP MANAGER-1 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 relationship] requires rep risk and we can move 
ahead so long as nothing further is identified through KYC and AML client adoptions." The 
Bank has represented to the Department that it has no other record of this communication 
between EXECUTIVE-1 and the other officers, and the ARRC did not meet in connection with 
the initial onboarding of Mr. Epstein. 
23. 
"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 provide 
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that, should a Deutsche Bank business or compliance unit identify a client that they believe could 
pose a reputational risk to the Bank, they 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. 
24. 
The relationship between Deutsche Bank and Mr. 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, Mr. Epstein, his related entities, and associates would eventually open and fund 
more than 40 accounts at the Bank. 
25. 
A Bank AML compliance officer cleared the relationship based on EXECUTIVE-
l's Approval Email. The Bank represented that there is no indication that the AML compliance 
officer spoke directly with EXECUTIVE-1 or with the other Compliance or Legal officers 
mentioned in the Approval Email. 
Epstein Used Deutsche Bank Accounts to Engage in Suspicious Transactions 
26. 
From the time of Mr. Epstein's onboarding, the relationship was classified by 
Deutsche Bank as "high-risk" and therefore subject to enhanced due diligence. Although the 
Bank did not initially classify Mr. Epstein as a politically 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 resulted in enhanced 
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transaction monitoring of activity within Epstein's accounts. However, and as discussed below, 
this scrutiny was not tailored to the specific risks that he posed. 
27. 
As early as November 1, 2013, however, Mr. Epstein and his representatives 
began using Deutsche Bank accounts to send wires to people who had been alleged to be co-
conspirators in his past criminal offenses. Over the course of the relationship, Mr. 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 alleged co-conspirators who had 
been the subject of past press reports, including CO-CONSPIRATORS-1, -2, and -3. The Bank 
was not always aware that the recipients of wire transfers were alleged co-conspirators. For 
example, the wire transfers in November 2013 were made to an entity that was only later 
publicly associated with a co-conspirator (in 2015). As described further below, however, the 
connection was made by Bank personnel for certain transactions. 
28. 
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, CO-CONSPIRATORS 1-3, and a number of 
women with Eastern European surnames. When Bank personnel asked Epstein and Epstein's 
representatives about his relationship with the beneficiaries, Epstein represented that they were 
employees or friends. The 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." 
29. 
The Butterfly Trust accounts were, like the overall Epstein relationship itself, 
approved for onboarding based on the earlier Approval Email from EXECUTIVE-1, despite 
apparent reputational and possible financial crime risks. Specifically, the beneficiaries of the 
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Butterfly Trust included, among others, CO-CONSPIRATORS 1-3. The existence of co-
conspirators as beneficiaries of the trust created the very real risk that payments through the 
Trust could be used to further or coverup criminal activity and perhaps even to endanger more 
young women. 
30. 
At the time of onboarding of the Butterfly Trust accounts, Bank personnel were 
aware that one of the Trust's beneficiaries was an alleged co-conspirator of Epstein's prior 
offenses. In October 2013, a compliance officer performed background checks on the 
beneficiaries of the trust and flagged for RELATIONSHIP COORDINATOR-1 that one of the 
beneficiaries, CO-CONSPIRATOR-2, had been alleged to be one of Epstein's co-conspirators. 
In reply RELATIONSHIP COORDINATOR-1 confirmed that "[CO-CONSPIRATOR-2] 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 Executive-1. 
31. 
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, including some transfers to alleged co-conspirators or women with Eastern 
European surnames, for the stated purpose of covering hotel expenses, tuition, and rent. 
32. 
Although payments related to legal expenses are not inherently suspicious, Mr. 
Epstein also used his various accounts for what appear to have been multiple settlement 
payments totaling over $7 million to law firms, as well as dozens of payments to law firms 
totaling over $6 million for what appear to have been the legal expenses of Mr. Epstein and co-
conspirators. 
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ARRC's Consideration of the Epstein Relationship 
33. 
At the end of 2014 and into 2015, the Bank's Anti-Financial Crime department 
escalated issues concerning Mr. Epstein. The first issue arose in connection with the Bank's 
opening of a Global Markets account for Mr. Epstein. In January 2015, during the onboarding 
process for that account, an AML Compliance Officer ("AML OFFICER-1") identified recent 
developments in the press concerning Mr. Epstein, including (a) a June 2014 federal appeals 
court ruling that some of Mr. Epstein's alleged victims would be granted access to the details of 
the 2008 plea bargain, potentially reopening their cases, and (b) additional allegations in the 
press regarding Mr. Epstein's relationships with a prominent former U.S. politician and a 
member of a European royal family. 
34. 
AML OFFICER-1 escalated these issues to a more senior AML officer ("AML 
OFFICER-2"). In response, AML OFFICER-2 initially noted that the same negative allegations 
against Epstein had been approved by EXECUTIVE-1, the former Head of AML and the former 
General Counsel for the Americas and attached a copy of the Approval Email. AML OFFICER-1 
responded that they should still run the issue by the then Head of AFC Americas because: the 
Approval Email was "not a direct approval by [the Head of AML Compliance for Deutsche Bank 
Americas and the [then] General Counsel for Deutsche Bank Americas]; it's a statement by a 
front office MD about his conversation with them and their alleged opinion not to escalate to Rep 
Risk;" the Head of AML Compliance was no longer at the Bank; and there were new 
developments in Epstein's case that could lead to the reopening of his 2008 conviction. 
35. 
As a result of these discussions and additional media reports regarding Epstein's 
association with prominent political figures, AML OFFICER-2 put the question of whether to 
escalate before EXECUTIVE-2, who agreed to escalate to the ARRC. In the email to 
EXECUTIVE-2, AML OFFICER-2 noted that the communication underpinning the Approval 
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Letter occurred before these new developments and for further background also noted, among 
other things, that "[b]y 2011, 40 underage girls had come forward with testimony of Epstein 
sexually assaulting them" and that "Epstein [had] managed to settle at least 17 lawsuits out of 
court." 
36. 
Later that month, on January 22, 2015, in preparation for the ARRC meeting, 
EXECUTIVE-1 and RELATIONSHIP MANAGER-1 met in person with Mr. Epstein at his New 
York home. During the meeting, EXECUTIVE-1 asked Mr. Epstein about the veracity of the 
recent allegations and appeared to be satisfied by Mr. Epstein's response. The Bank has 
represented to the Department that it is not in possession of contemporaneous records reflecting 
the substance of EXECUTIVE-1's meeting with Epstein and is not aware of any other steps 
taken at the time to investigate the veracity of the allegations beyond speaking with Mr. Epstein. 
37. 
On January 30, 2015, members of the ARRC met to discuss the Epstein 
relationship. Despite the fact that Deutsche Bank's policies and procedures mandate that detailed 
minutes of such meetings be kept, the Bank has represented to the Department that there are no 
recorded minutes from that particular meeting. Later that day, however, a member of the ARRC 
emailed EXECUTIVE-1 to say, without explanation, that the committee was "comfortable with 
things continuing" with Mr. Epstein, and that another member of the committee had "noted a 
number of sizable deals recently." 
Conditions on the Epstein Relationship Were Communicated to Neither the Relationship 
Managers nor the Relevant Transaction Monitoring Team 
38. 
The following week, another member of the ARRC (the Bank's Head of 
Compliance, Americas) reiterated the ARRC's decision in an email to other executives, stating 
that ARRC had agreed to "continue business as usual with Jeff Epstein based upon 
[EXECUTIVE-1]'s due diligence visit with him." 
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39. 
That same email outlined three conditions, however, that the ARRC placed on the 
relationship: 
a. Mr. Epstein would be allowed to continue to "conduct trades and transactions in 
existing accounts without Compliance pre-approval, provided that the business 
had determined these transactions do not involve any unusual and/or suspicious 
activity or are in a size that is unusually significant or novel in structure." 
b. The Bank's Corporate Banking and Securities unit would be allowed to "also 
'open' accounts to facilitate activity as a booking matter where the activity has 
already been approved by [the Bank's America's Wealth Management division]." 
c. The business would "need to monitor for any further developments in connection 
with the reputational risk of the client relationship and to review 
transactions/activity conducted in the accounts for any activity, size or structure as 
described in [the first condition]." 
40. 
These mandatory conditions were communicated to several senior Bank 
personnel, up to and including the Bank's CEO of the Americas. Inexplicably, however, they 
were apparently never communicated to all members of the Epstein relationship team. Epstein's 
relationship managers continued conducting business with Epstein in the same manner as they 
had prior to the ARRC meeting. 
41. 
This failure was then substantially compounded when AML OFFICER-2 
purportedly misinterpreted the conditions; as a result they were also not communicated to the 
transaction monitoring team responsible for monitoring the Epstein relationship. Specifically, 
AML OFFICER-2 interpreted the clause "transactions [with] unusual and/or suspicious activity 
or are in a size that is unusually significant or novel in structure" to mean transactions that were 
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unusual, suspicious, or novel as compared to the prior history of transactions related to the 
Epstein relationship. He communicated this interpretation to the rest of the transaction 
monitoring team responsible for the Epstein relationship. The interpretation was exemplified by 
a later email exchange in March of 2017, when a member of the transaction monitoring team 
responded to an alert about payments to a Russian model and Russian publicity agent, stating, 
"[Once this type of activity is normal for this client it is not deemed suspicious." 
42. 
Instead of monitoring the accounts for all potential crimes and suspicious activity 
that could be implicated by Mr. Epstein's alleged past conduct, including payments to co-
conspirators and those that could be related to sex trafficking involving adults, AML OFFICER-
2 only instructed the relevant transaction monitoring team to verify, using intemet searches, that 
any woman involved with transactions related to the Epstein relationship was at least 18 years 
old and to only flag transactions if they could not discern a rational reason for the transaction, a 
standard which had little if any effect on the Bank's relationship with Mr. Epstein. 
The Bank Continued to Maintain the Relationship for Years Despite Additional Red Flags 
43. 
On July 21, 2015, Mr. Epstein requested an increase in his trading limits. Several 
days later, a member of Epstein's coverage team ("COVERAGE TEAM MEMBER-1"), who 
was aware of the ARRC's conditions on the relationship, escalated this request to AML 
OFFICER-2, who in turn escalated the issue to the Chairman of the ARRC. On July 29, 2015, 
after conferring with other members of the ARRC but without formally meeting, the Chairman 
replied to AML OFFICER-2 stating they had no objections. The Chairman added, "I also 
checked in with [EXECUTIVE-1] last night to make sure he supports this and has heard nothing 
negative on the client. [EXECUTIVE-1] confirmed both." 
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44. 
On January 4, 2016, an accountant representing Mr. Epstein (herein, 
"ACCOUNTANT-1") requested that the Bank open a brokerage account for Gratitude America, 
Mr. Epstein's private charity. COVERAGE TEAM MEMBER-1 escalated the request to AML 
OFFICER-2, who directed the inquiry to the Secretary for the ARRC. The Secretary of the 
ARRC conferred with a member of the ARRC and ordered that an external due diligence report 
be prepared on Mr. Epstein. In response to the request for additional information, 
ACCOUNTANT-1 informed the Bank of Mr. Epstein's resignation from Gratitude America and 
withdrew the request to open the account. As a result, no due diligence report was run on Mr. 
Epstein. 
45. 
By April 2016, RELATIONSHIP MANAGER-1 was replaced by another 
relationship manager (herein, "RELATIONSHIP MANAGER-2") to handle accounts associated 
with Mr. Epstein. Although RELATIONSHIP MANAGER-2 had Mr. Epstein's KYC file and 
had been made aware of the prior escalation of the relationship to the ARRC, he was not made 
aware by anyone at the Bank of the three conditions the ARRC placed on the relationship after 
its February 2015 review. 
46. 
In a May 2018 email, a compliance officer submitted an inquiry to 
RELATIONSHIP MANAGER-2 about payments to the accounts of women with Eastern 
European surnames at a Russian bank, and asking for an explanation of the purpose of the wire 
transactions and Epstein's relationship with the counterparties. After submitting the questions to 
ACCOUNTANT-1, RELATIONSHIP MANAGER-2 forwarded ACCOUNTANT-1's response 
to the compliance officer, which read "SENT TO A FRIEND FOR TUITION FOR SCHOOL." 
When the compliance officer followed up, asking "[w]tty is this client using this account to . . . 
pay school tuition?," RELATIONSHIP MANAGER-2 replied "[g]enerally, Jeffrey has separate 
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accounts to manage each of his properties. This is one of them. However, when making one-off 
transfers to people, he and his finance staff have the flexibility to use any account they like that 
is funded." The Bank has represented to the Department that it has no records of the compliance 
officer asking further follow-up questions, and the transaction was cleared. 
47. 
In addition, payments from the Butterfly Trust accounts and other Epstein 
accounts were used for lawsuit settlement payments to alleged victims, and rent, legal, and 
immigration expenses made to or on behalf of young (albeit adult) women, including additional 
women with Eastern European surnames. 
Deutsche Bank Was Aware of Suspicious Cash Activity Throughout the Relationship 
48. 
Several of Mr. Epstein's employees or agents had authority to conduct 
transactions in the accounts on Mr. Epstein's behalf. One of them, Mr. Epstein's personal 
attorney (herein, "ATTORNEY-1"), was active in withdrawing cash for Mr. Epstein. 
ATTORNEY-1, on behalf of Mr. Epstein, made a total of 97 withdrawals from the Bank's Park 
Avenue (New York City) Branch from 2013 to 2017 from personal accounts belonging to Mr. 
Epstein. The transactions in question occurred roughly two to three times per month, all in the 
amount of $7,500 per withdrawal, the Bank's limit for third-party withdrawals (Le., withdrawals 
made by an authorized user who is not a primary account holder). When Bank personnel asked 
ATTORNEY-1 why Epstein needed cash, ATTORNEY-1 replied Epstein used it for travel, 
tipping and expenses. 
49. 
Under federal regulations, banks and other financial institutions must file 
Currency Transaction Reports ("CTRs") with the U.S. Treasury Department when there are cash 
transactions with an individual in excess of $10,000 in one day. Breaking up transactions to 
avoid the CTR reporting is a criminal offense commonly referred to as "structuring." When 
ATTORNEY-1's cash activity triggered reporting requirements, the Bank complied and filed the 
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requisite CTRs. The Bank also monitored ATTORNEY-1 's activity for suspicious activity 
reporting. 
50. 
In May 2014, ATTORNEY-1 inquired into how often he could withdraw cash on 
behalf of Mr. Epstein without triggering an alert. The record is unclear as to whether anyone 
from the Bank ever responded to ATTORNEY-1's inquiry. RELATIONSHIP COORDINATOR-
I sent an email to the branch manager stating that ATTORNEY-1 "asked how often they could 
come in to withdraw cash without creating some sort of alert," and asking "Is it once a week? 
Twice a week? Once every other week?" The Bank has represented that it has no record of any 
response. RELATIONSHIP COORDINATOR-1 has since represented that she understood 
ATTORNEY-1's inquiry related to ATTORNEY-1's desire to withdraw more than the $7,500 
limit for third-party withdrawals, and not to CTR filing requirements. 
51. 
In 2017, ATTORNEY-1 again inquired about triggering an alert. Specifically, in 
July 2017, ATTORNEY-1 had, among other things, asked a teller whether a withdrawal 
transaction in excess of $10,000 would require reporting and, upon being advised that it would, 
broke up the withdrawal transaction over two days. In July of that year, members of the Bank's 
Wealth Management AML transaction monitoring team, including AML OFFICER-2, met to 
discuss suspicions of cash structuring to avoid currency transaction reports ("CTRs") by 
ATTORNEY-1. AML OFFICER-2, among others, spoke with ATTORNEY-1 and advised that 
(a) his patterns gave the appearance of structuring, (b) this pattern was unacceptable, and (c) he 
would be provided with additional information about CTR reporting requirements. 
ATTORNEY-1 represented that he had not intended to structure cash withdrawals. Bank 
personnel found ATTORNEY-I credible and permitted him to continue to withdraw cash from 
his own and Epstein's accounts. In 2018, just prior to the Bank's closing of the Park Avenue 
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Branch, which was located nearby Mr. Epstein's house, ATTORNEY-1 withdrew $100,000.00 
in cash on behalf of Mr. Epstein. When later questioned why ATTORNEY-1 withdrew these 
sums from the Bank, ATTORNEY-1 reported that Mr. Epstein needed the funds for tipping and 
household expenses. 
52. 
In total, in a roughly four-year period, ATTORNEY-1 withdrew on Mr. Epstein's 
behalf more than $800,000 in cash from Mr. Epstein's personal accounts. Throughout the 
Epstein relationship the Bank filed CTRs appropriately, but there is no indication that the Bank 
ever sought or received any explanation for Epstein's cash activity beyond the travel, tipping, 
and expenses explanation provided by ATTORNEY-1. 
Termination of the Epstein Relationship 
53. 
In November 2018, the Miami Herald released an article on Mr. Epstein detailing 
his 2008 plea deal. The article prompted senior members of Wealth Management to reassess the 
relationship's reputational risk and ultimately terminate the Epstein Relationship. On December 
21, 2018, the Bank informed Mr. Epstein by letter that they would no longer be servicing his 
accounts. 
54. 
Despite the Bank's decision to offboard all Epstein accounts due to reputational 
risks, RELATIONSHIP MANAGER-2 drafted reference letters to two other financial 
institutions, on Deutsche Bank letterhead, indicating in one such letter that he was "unaware of 
any problems relating to the operation or use of [the] accounts." 
Conclusions Reeardine the Epstein Accounts 
55. 
If a financial institution decides to do business with a high-risk client, that 
institution is required to conduct due diligence commensurate with that risk and to tailor its 
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transaction monitoring to detect suspicious or unlawful activity based on what the risk is. In this 
case, Deutsche Bank failed to do so. 
56. 
The Bank's fundamental failure was that, although the Bank properly classified 
Mr. Epstein as high-risk, the Bank failed to scrutinize the activity in the accounts for the kinds of 
activity that were obviously implicated by Mr. Epstein's past. The Bank was well aware not only 
that Mr. Epstein had pled guilty and served prison time for engaging in sex with a minor but also 
that there were public allegations that his conduct was facilitated by several named co-
conspirators. Despite this knowledge, the Bank did little or nothing to inquire into or block 
numerous payments to named co-conspirators, and to or on behalf of numerous young women, or 
to inquire how Mr. Epstein was using, on average, more than $200,000 per year in cash. 
57. 
Whether or to what extent those payments or that cash was used by Mr. Epstein to 
cover up old crimes, to facilitate new ones, or for some other purpose are questions that must be 
left to the criminal authorities, but the fact that they were suspicious should have been obvious to 
Bank personnel at various levels. The Bank's failure to recognize this risk constitutes a major 
compliance failure. 
58. 
This substantive failure was compounded by a series of procedural failures, 
mistakes, and sloppiness in how the Bank managed and oversaw the Epstein accounts. Despite 
the nature of Mr. Epstein's prior criminal history, the initial onboarding of the first account was 
not reviewed by the Bank's regional reputational risk committee but was instead approved in 
what appears to have been an off-hand conversation reflected only in the Approval Email. That 
Approval Email was then relied upon, substantially without additional scrutiny, to open 
numerous other Epstein-related accounts. When the relationship was finally elevated to the full 
ARRC in early 2015, no minutes were taken of that meeting, contrary to Bank policy, and the 
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committee was satisfied enough to continue the relationship based primarily on a brief due 
diligence meeting between two front-office personnel and Mr. Epstein himself, the substance of 
which was also not reflected in writing. Moreover, the conditions imposed by the ARRC — 
conditions that, if followed, might have detected and prevented many subsequent suspicious 
transactions — (a) were not transmitted to the majority of the relationship team; and (b) were 
misinterpreted by a compliance officer in a way that resulted in very little change in how the 
monitoring of the accounts occurred going forward. Throughout the relationship, very few 
problematic transactions were ever questioned, and when they were, they were usually cleared 
without satisfactory explanation. 
59. 
These errors are unacceptable in the context of a major international bank and 
inexcusable in the context of the heightened scrutiny that should have occurred in the monitoring 
of a high-risk customer. 
C. 
The Bank's Correspondent Banking Relationships with FBME and Danske Bank 
60. 
Deutsche Bank has had correspondent banking relationships with foreign banks, 
including several that were in high-risk jurisdictions or themselves had customers operating in 
high-risk industries. The Department has concluded that Deutsche Bank failed to adequately 
monitor and manage those relationships, including, in particular, with FBME and Danske. 
FBME 
61. 
In 1982, FBME was established in Cyprus as a subsidiary of the Federal Bank of 
Lebanon, which was founded in 1952. 
62. 
In January 1984, FBME opened a correspondent banking account with Bankers 
Trust, which Deutsche Bank acquired in 1999 and later renamed to Deutsche Bank Trust 
Company Americas, though this account was mostly unused for years as FBME did limited 
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