Deutsche Bank

Deutsche Bank maintained extensive lobbying apparatus: 142 total filings spanning 2002-present. In 2007 (Epstein NPA year), DB lobbied on Anti-Money Laundering and Hedge Fund Regulation (200K H1, 450K H2 = 650K total). In 2019 (Epstein arrest year), DB lobbied via Tiber Creek Group at 150-210K/quarter (660K total) on Dodd-Frank reform, financial services regulation, trade, and cybersecurity. Key lobbyists: Jeffrey Peck, Drew Cantor. Notable: DB was simultaneously lobbying on AML/banking regulation while maintaining 40+ Epstein accounts and processing 2.65M via Butterfly Trust to co-conspirators. 29 LD-203 contribution reports filed, including contributions to Schumer, Shelby, Barney Frank, Gillibrand, and Harry Reid.

Deutsche Bank Securities Inc filed 29 LD-203 contribution reports. Notable political contributions from DB registered lobbyists include: Schumer (2.5K, 2010), Gillibrand (multiple 2.4-2.5K, 2009-2010), Harry Reid (1.5K, 2010), Barney Frank (5K, 2010), Shelby (5K, 2010), Kanjorski (5K, 2008; 2.7K, 2010), Jim Himes (2.5K, 2010), Kelly Ayotte (2.5K, 2010), Stabenow (5K, 2010), and DCCC (5K, 2008). These contributions went to members of the Senate Banking Committee and House Financial Services Committee who oversaw banking regulation, including AML/BSA enforcement that would later result in Deutsche Bank's 150M NYDFS penalty for Epstein-related AML failures.

LMSBAND dataset contains a Deutsche Bank 1MDB article (EFTA01384845) documenting DB's investigation for possible foreign corruption or anti-money-laundering violations in its work for 1MDB. Headlines captured: 'Deutsche Bank Caught Up in Scandal Over Malaysian 1MDB Fund' (NYT), 'Deutsche Bank latest headache: Its role in Malaysia 1MDB scandal' (CNN), 'US Investigating Deutsche Bank Dealings With Malaysian Fund 1MDB' (WSJ). This is significant because Deutsche Bank maintained 40+ Epstein accounts simultaneously. The DOJ Vol 11 article (EFTA02466190) specifically notes: 'Deutsche Bank, as 1MDB banker, was involved in sending 1 billion of the funds money out of the country in 2009' and 'the US Department of Justice has asked banks including Deutsche Bank AG and J.P. Morgan Chase for documents related to their interactions with 1MDB.' Both DB and JPM -- Epstein's two primary banks -- were implicated in the 1MDB probe.

ATTORNEY-1 (Epstein personal attorney) withdrew over $800,000 in cash from Epstein personal accounts over roughly four years (2013-2017), making 97 withdrawals from DB Park Avenue Branch at $7,500 each (bank third-party withdrawal limit). In May 2014, ATTORNEY-1 asked how often he could withdraw without triggering alerts. In July 2017, ATTORNEY-1 broke up a withdrawal over $10K into two days to avoid CTR filing — bank confronted but found him credible. In 2018, ATTORNEY-1 withdrew $100,000 in single cash withdrawal prior to branch closing.

Bank filed CTRs but never sought explanation beyond ATTORNEY-1 claim of travel, tipping, and expenses. ATTORNEY-1 inquired about alert thresholds in May 2014 — RELATIONSHIP COORDINATOR-1 asked branch manager about frequency limits but no response recorded. In July 2017, ATTORNEY-1 asked teller if withdrawal over $10K would require reporting, then broke transaction over two days — textbook structuring behavior. AML OFFICER-2 team confronted ATTORNEY-1 about pattern. Bank personnel found ATTORNEY-1 credible and allowed continued withdrawals. Cash structured at just below reporting thresholds across 97 transactions. Park Avenue Branch was located nearby Epstein house.

DB onboarded Epstein in August 2013 through RELATIONSHIP MANAGER-1, who had previously serviced Epstein at US BANK-1 (competitor bank, likely JPMorgan). RM-1 joined DB Nov 2012, pitched Epstein as generating '$100-300M flows overtime with revenue of $2-4M annually.' Proposed all accounts be for entities, not personal accounts. Onboarding approved via informal email from EXECUTIVE-1 (Co-Head of Wealth Management Americas) citing conversations with Head of AML Compliance and General Counsel — but no ARRC review occurred.

RM-1 proposed relationship in spring 2013. Junior coordinator RELATIONSHIP COORDINATOR-1 prepared memo containing Epstein criminal history (2007 plea, 13-month sentence, accusations of paying young women for massages, 17 out-of-court settlements). EXECUTIVE-1 sent Approval Email on May 5, 2013 stating neither Head of AML nor General Counsel suggested rep risk review needed. Bank has no other record of this conversation. ARRC did not meet for initial onboarding. AML compliance officer cleared relationship based solely on Approval Email without speaking directly to parties mentioned.

NYDFS Consent Order (2020) confirms Deutsche Bank maintained 40+ accounts for Epstein entities from Aug 2013 to Dec 2018. DB classified relationship as 'high-risk' but failed to properly monitor. Butterfly Trust included co-conspirators as beneficiaries. Over 120 wires totaling $2.65M sent to beneficiaries including women with Eastern European surnames. Payments to 'a Russian model and Russian publicity agent' deemed 'normal for this client.' ARRC conditions never communicated to relationship team. $150M penalty.

Epstein used DB accounts for over $7M in settlement payments to law firms (apparent victim settlements) plus over $6M in legal expenses for Epstein and co-conspirators. Also sent over 120 wires totaling $2.65M to Butterfly Trust beneficiaries including at least 18 wires of $10K+ to named co-conspirators (CO-CONSPIRATORS 1, 2, 3). Payments included hotel expenses, tuition, rent, and immigration expenses for young women with Eastern European surnames.

Wire activity to co-conspirators began November 1, 2013, within weeks of account opening. Some early wires to entity only later publicly associated with co-conspirator (2015). Butterfly Trust opened Jan 24, 2014 — checking and money market accounts. Beneficiaries included CO-CONSPIRATORS 1-3 and women with Eastern European surnames. Epstein told bank they were employees or friends. KYC stated trust purpose was to pay taxes and trust fees. May 2018 compliance inquiry about payments to women at Russian bank — cleared after ACCOUNTANT-1 replied SENT TO A FRIEND FOR TUITION FOR SCHOOL and RM-2 explained Epstein had flexibility to use any funded account. March 2017 alert about payments to Russian model and Russian publicity agent cleared with note: since this type of activity is normal for this client it is not deemed suspicious.

Epstein requested trading limit increase on July 21, 2015. COVERAGE TEAM MEMBER-1 escalated to AML OFFICER-2, who escalated to ARRC Chairman. Chairman approved without formal meeting, adding: 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.

This shows that EXECUTIVE-1 continued to actively support the Epstein relationship as late as July 2015, six months after the ARRC review. The informal approval process — Chairman checking in with EXECUTIVE-1 by phone — mirrors the same ad hoc governance that characterized the initial onboarding. The ARRC Chairman did not convene a formal meeting but instead polled members individually and approved. The reference to EXECUTIVE-1 hearing nothing negative on the client suggests EXECUTIVE-1 was monitoring the relationship and providing ongoing assurance.

Gratitude America (Epstein private charity) account opening attempted in January 2016. ACCOUNTANT-1 requested brokerage account. COVERAGE TEAM MEMBER-1 escalated to AML OFFICER-2, then to ARRC Secretary. External due diligence report ordered on Epstein — but ACCOUNTANT-1 informed bank of Epstein resignation from Gratitude America and withdrew account request, so NO due diligence report was actually run.

This is significant because it shows that even when an opportunity arose in 2016 to conduct proper due diligence on Epstein, the request was withdrawn before execution, meaning DB went through the entire relationship (2013-2018) without conducting an external due diligence report on Epstein. The withdrawal of the Gratitude America request itself is suspicious — suggests Epstein or his representatives wanted to avoid scrutiny.

May 2018: Compliance officer inquired about Epstein payments to accounts of women with Eastern European surnames at a Russian bank. RELATIONSHIP MANAGER-2 forwarded ACCOUNTANT-1 response: SENT TO A FRIEND FOR TUITION FOR SCHOOL. When compliance asked why this account was being used to pay school tuition, RM-2 explained Epstein had flexibility to use any account. No further follow-up questions recorded and transaction was cleared.

This May 2018 incident, just seven months before the relationship was terminated, shows the monitoring failure pattern: (1) Compliance flags suspicious activity — payments to Eastern European women at Russian bank. (2) RM obtains explanation from Epstein side — generic claim about tuition for a friend. (3) Compliance accepts explanation despite it making little business sense. (4) No further investigation. The consent order notes the Bank has represented it has no records of the compliance officer asking further follow-up questions. This is one of the most specific examples of how the monitoring failure enabled Epstein to continue using accounts for potentially suspicious purposes.

Deutsche Bank had dual exposure to both 1MDB and Epstein networks simultaneously. DB was investigated by DOJ for possible FCPA/AML violations related to 1MDB fund work (EFTA01384845: 'Deutsche Bank faces US investigation over work for Malaysia 1MDB fund'). DB also maintained 40+ Epstein accounts with $2.65M flowing via Butterfly Trust to co-conspirators. DB lobbied on 'Anti-Money Laundering' issues in H1 2007 while maintaining Epstein accounts. The Wildman v. Deutsche Bank case (EDNY 2021, 2nd Cir 2023) is a 1MDB-related shareholder suit. Doe 1 v. Deutsche Bank (SDNY 2022) is the Epstein victim case. Both involved the same bank's compliance failures.

Deutsche Bank had 4 FARA-registered foreign principal entries through 3 different registrants: Sullivan & Worcester (#2843, 1977-1985), TransAtlantic Futures Inc (#4353, 1990-1992), and Van Scoyoc Associates (#5401, 2003). The Van Scoyoc registration for Deutsche Bank AG New York Branch (2003) overlaps with the period Deutsche Bank maintained 40+ accounts for Epstein and facilitated $2.65M via Butterfly Trust. Deutsche Bank's FARA registrations confirm it was actively lobbying US government while simultaneously serving as Epstein's primary banking relationship.

NYDFS consent order identifies Epstein as 'Honorary PEP' at Deutsche Bank — not formally classified as politically exposed person, but given informal designation due to connections to prominent political figures. This resulted in enhanced transaction monitoring but monitoring was not tailored to the specific risks he posed (sex trafficking, payments to co-conspirators).

The Honorary PEP designation combined with high-risk classification should have triggered comprehensive monitoring. Instead, AML OFFICER-2 narrowly interpreted monitoring to only check if women in transactions were at least 18 years old. The failure to tailor monitoring to known risks (co-conspirator payments, trafficking, cash structuring) was the central compliance failure per NYDFS.

October 2013: DB compliance officer performed background checks on Butterfly Trust beneficiaries and flagged CO-CONSPIRATOR-2 as alleged Epstein co-conspirator. RELATIONSHIP COORDINATOR-1 confirmed CO-CONSPIRATOR-2 was 'accused as a co-conspirator in a case but was never brought to trial nor ever convicted.' Alert was cleared citing the Approval Email from EXECUTIVE-1. Trust was onboarded despite known co-conspirator beneficiary.

This finding demonstrates that DB personnel knew before the Butterfly Trust opened (Jan 24, 2014) that at least one beneficiary was an alleged co-conspirator. The compliance flag was explicitly cleared based on EXECUTIVE-1 Approval Email — an informal email that was never intended as blanket approval for all Epstein-related accounts. CO-CONSPIRATOR-2 identity is redacted in consent order but publicly known from other court filings. The trust created risk that payments could be used to further or coverup criminal activity and perhaps even to endanger more young women per NYDFS.

ARRC reviewed Epstein relationship on January 30, 2015 after AML OFFICER-1 escalated new press reports (June 2014 appeals court ruling on Epstein plea, allegations involving prominent US politician and European royal). No minutes taken of meeting (violating bank policy). Committee was 'comfortable with things continuing,' noting 'a number of sizable deals recently.' Three conditions imposed but never communicated to relationship team or transaction monitoring team.

Before ARRC meeting, EXECUTIVE-1 and RELATIONSHIP MANAGER-1 met Epstein at his NY home on Jan 22, 2015. No contemporaneous records of meeting substance. AML OFFICER-1 had flagged that Approval Email was 'not a direct approval' — just a front office MD reporting conversations. AML OFFICER-2 escalated to ARRC noting '40 underage girls had come forward' and '17 lawsuits settled.' ARRC conditions: (1) trades in existing accounts without compliance pre-approval unless unusual/suspicious, (2) CBS unit could open booking accounts for approved activity, (3) business must monitor for further developments and review activity. Conditions communicated to senior personnel up to CEO of the Americas — but NOT to relationship managers. AML OFFICER-2 misinterpreted conditions to mean unusual only relative to prior Epstein history, resulting in March 2017 clearance of Russian model payments as 'normal for this client.' RM-2 replaced RM-1 in April 2016 and was never informed of ARRC conditions.

ARRC Head of Compliance Americas characterized Jan 2015 ARRC decision as: continue business as usual with Jeff Epstein based upon [EXECUTIVE-1] due diligence visit with him. This explicitly tied continued approval to a single in-person meeting between EXECUTIVE-1/RM-1 and Epstein at his New York home on January 22, 2015 — no independent investigation, no external due diligence, substance of meeting never documented.

The quote reveals that the ARRC decision to continue was based primarily on EXECUTIVE-1 personal visit and assurances. The January 22, 2015 meeting at Epstein NY home was conducted by two front-office personnel (EXECUTIVE-1 and RELATIONSHIP MANAGER-1) — neither AML nor compliance officers attended. EXECUTIVE-1 asked Epstein about veracity of recent allegations and appeared to be satisfied by response. Bank has no contemporaneous records of meeting substance and is not aware of any other steps taken to investigate beyond speaking with Epstein himself.

Deutsche Bank had prior independent monitor engaged per January 30, 2017 Consent Order. NYDFS directed that existing monitor address the Epstein/FBME/Danske compliance failures within the timetable of that engagement. Department reserved right to extend scope or duration of monitorship.

This reveals that DB was already under enhanced NYDFS supervision (monitorship) since January 2017 — while still maintaining Epstein accounts through December 2018. The 2017 consent order was for separate compliance issues. DB was simultaneously being monitored for prior AML failures while continuing to fail at monitoring Epstein accounts. The 2020 consent order added the Epstein/FBME/Danske failures to the existing monitors scope rather than requiring a new monitor.

AML OFFICER-2 misinterpreted ARRC conditions on Epstein monitoring: instead of monitoring for all potential crimes implicated by Epstein past (payments to co-conspirators, sex trafficking), officer only instructed transaction monitoring team to verify via internet searches that any woman in transactions was at least 18 years old, and to only flag transactions if no rational reason could be discerned. This standard had little if any effect on monitoring.

The misinterpretation was exemplified by March 2017 email exchange: member of transaction monitoring team responded to alert about payments to a Russian model and Russian publicity agent, stating: since this type of activity is normal for this client it is not deemed suspicious. The ARRC clause about unusual and/or suspicious activity or are in a size that is unusually significant or novel in structure was interpreted to mean unusual only relative to prior Epstein transaction history — effectively defining away all suspicious activity as normal baseline.

After DB terminated Epstein relationship in December 2018, RELATIONSHIP MANAGER-2 drafted reference letters to two other financial institutions on Deutsche Bank letterhead, stating in one letter he was 'unaware of any problems relating to the operation or use of [the] accounts.' This despite the reputational-risk-based termination and the full history of compliance concerns.

Bank informed Epstein by letter on December 21, 2018 that they would no longer service his accounts, triggered by November 2018 Miami Herald article detailing 2008 plea deal. Despite the bank decision to offboard ALL Epstein accounts due to reputational risk, RM-2 provided reference letters to help Epstein move to other banks. This is investigatively significant — identifies RM-2 as potentially sympathetic to Epstein even after termination.

NYDFS imposed $150M penalty on Deutsche Bank for AML failures related to Epstein, FBME, and Danske Estonia relationships. Consent Order signed July 6, 2020 under NY Banking Law Sections 39 and 44. Bank found to have conducted business in unsafe and unsound manner (Section 44 violation) and failed to maintain effective AML program (3 NYCRR Section 116.2 violation).

Consent Order between NYDFS, Deutsche Bank AG, Deutsche Bank AG New York Branch, and Deutsche Bank Trust Company of the Americas. Penalty of $150,000,000 payable within 10 business days. Bank agreed not to claim tax deductions or seek insurance reimbursement for penalty. Independent monitor already engaged per prior January 30, 2017 Consent Order directed to address these additional failures.

DB consent order correspondent banking compliance failures: bank failed to maintain policies with specific criteria for when to terminate correspondent banking relationships (e.g., patterns of high RAC scores, high suspicious activity volumes). Failed to maintain policies for closure of accounts based on failure to obtain/update USA PATRIOT Act certifications. Failed to maintain policies with practical guidance for determining whether other foreign banks use the respondent account, or for verifying beneficial owner identities.

These systemic policy failures applied across the DB correspondent banking business, not just to FBME and Danske Estonia. The absence of termination criteria meant that even maximum risk scores (RAC 10 for Danske Estonia) and hundreds of suspicious transactions did not trigger automatic account closure review. The policy gaps were structural — no clear off-ramp existed for high-risk correspondent relationships regardless of how many red flags accumulated.

Deutsche Bank lobbied specifically on Anti-Money Laundering issues in H1 2007 while simultaneously maintaining 40+ Epstein accounts that would later result in 150M NYDFS penalty. DB spent 200K on AML/hedge fund/securities regulation lobbying in H1 2007 and 450K on mortgage/hedge fund/securities in H2 2007. This lobbying occurred during the exact period (2006-2008) when Epstein's NPA was being negotiated and when DB was processing suspicious transactions for Epstein entities. The juxtaposition of lobbying to influence AML regulation while facilitating suspicious transactions for a known sex offender is investigatively significant.

Epstein modeling agency connection flagged in consent order: press reports noted allegations that Epstein was involved with Eastern European women and that a modeling agency he helped fund brought young girls, often from Eastern Europe to the US on Epstein private jets. This was publicly known before DB onboarding in 2013.

The consent order cites pre-2013 press reports about a modeling agency funded by Epstein that brought Eastern European young women to the US. This is likely a reference to MC2 Model Management, which Epstein helped fund and was run by Jean-Luc Brunel. The NYDFS order implicitly criticizes DB for onboarding Epstein despite awareness of this trafficking-adjacent infrastructure. Payments to women with Eastern European surnames then continued through DB accounts including the Butterfly Trust.

DB consent order identifies key anonymous individuals in Epstein relationship: RELATIONSHIP MANAGER-1 (joined DB Nov 2012 from US BANK-1), RELATIONSHIP COORDINATOR-1 (junior coordinator), EXECUTIVE-1 (Co-Head Wealth Management Americas), EXECUTIVE-2 (COO Wealth Management Americas), AML OFFICER-1 and AML OFFICER-2 (compliance officers), RELATIONSHIP MANAGER-2 (replaced RM-1 in April 2016), ATTORNEY-1 (Epstein personal attorney who withdrew cash), ACCOUNTANT-1 (Epstein accountant), COVERAGE TEAM MEMBER-1, AML COMPLIANCE DIRECTOR-1 (former Director of US Anti-Financial Crimes).

Named signatories to the consent order: NYDFS side — Linda A. Lacewell (Superintendent), Katherine A. Lemire (Executive Deputy Superintendent), Kevin R. Puvalowski (Senior Deputy Superintendent), R. Bruce Wells (Associate Counsel), Terri-Anne Caplan (Sr. Asst. Deputy Superintendent for Enforcement), Randolph Hall (Asst. Counsel for Enforcement), Zachary Shapiro (Attorney for Enforcement). Deutsche Bank side — Karen Kuder (General Counsel), Thorsten Seyfried (General Counsel Germany/EMEA), Joe Salama (Global Head of Litigation and Regulatory Enforcement), Andrew Stemmer (Head of Litigation and Regulatory Enforcement Americas), Steven F. Reich (General Counsel Americas). US BANK-1 is likely JPMorgan based on public reporting.