EFTA00151495
regulatory orderNYDFS Consent Order — Deutsche Bank $150M Penalty for Epstein Compliance Failures
- Dataset
- Dataset 9: Bulk DOJ/DANY Correspondence
- Type
- REGULATORY ORDER
- Date
- July 7, 2020
- Pages
- 38
- Classification
- HIGH
- File Size
- —
Summary
New York Department of Financial Services Consent Order imposing $150M penalty on Deutsche Bank for significant compliance failures in banking Jeffrey Epstein (2013-2018). Details cascading failures: onboarding based on hearsay, ARRC meeting with no minutes, conditions never communicated, monitoring reduced to internet age-checks, 150+ suspicious transactions processed without SAR filings. First regulatory enforcement action against a financial institution for Epstein dealings.
Linked Entities2
| Name | Tier | Role |
|---|---|---|
| Jeffrey Epstein | T1 | subject |
| Richard D. Kahn | T6 | mentioned |
Cited In Stories6
NYDFS Consent Order — monitoring team member: "Once this type of activity is normal for this client it is not deemed suspicious"
p. p. 12NYDFS Consent Order — onboarding memo: "charged with soliciting an underage prostitution in 2007," 13 months served, 17 civil settlements
p. pp. 4-5NYDFS Consent Order — Paul Morris projection: "estimated flows of $100-300 [million]... w/ revenue of $2-4 million annually"
p. p. 3NYDFS Consent Order — EXECUTIVE-1 approval email: "Neither suggest [it] requires rep risk and we can move ahead"
p. p. 4NYDFS Consent Order — cascading compliance failures: conditions never communicated, monitoring reduced to internet age-checks, reference letters during offboarding
p. pp. 6-18NYDFS Consent Order — EXECUTIVE-1 and Morris home visit: "asked about the veracity of recent allegations and appeared to be satisfied"
p. p. 7