Deutsche Bank

Deutsche Bank AG is a global financial institution headquartered in Frankfurt, Germany, which operates a New York branch and a trust company, Deutsche Bank Trust Company of the Americas, licensed by the New York Department of Financial Services. The bank maintained a relationship with Jeffrey Epstein and his related entities from August 2013 until December 2018, taking him on after JPMorgan Chase dropped him and ending the relationship after renewed press attention to his 2008 plea deal. In July 2020 the New York Department of Financial Services imposed a 150 million dollar penalty for compliance failures centered on the Epstein relationship, at a time when the bank was already operating under an independent monitor imposed by a January 30, 2017 consent order, and in 2023 the bank agreed to pay 75 million dollars to settle a lawsuit by his victims. No federal enforcement action has been brought against the bank over Epstein.¹²³

Onboarding Epstein in 2013

In early 2013 Epstein began moving his assets to Deutsche Bank, brought in by a relationship manager who had previously serviced his accounts at a competitor bank and had joined Deutsche Bank's private wealth department in November 2012.¹ The relationship manager told senior management that Epstein could generate millions of dollars in revenue and leads for other clients, with one internal email estimating flows of 100 to 300 million dollars over time and revenue of 2 to 4 million dollars annually.¹ An April 2013 memorandum to the co-head of Wealth Management Americas and the division's chief operating officer disclosed Epstein's 2007 guilty plea to a prostitution charge and his 13 months in custody on an 18-month sentence.¹ Senator Ron Wyden's August 2026 report identified the relationship manager, "Relationship Manager-1" in the consent order, as Paul Morris, who had covered Epstein's accounts at JPMorgan Chase for a decade and whom JPMorgan due-diligence reviews named as Epstein's primary contact there. In September 2013 Morris emailed co-head of wealth management Chip Packard that "Epstein sending over about $200(million) from JP, told them Friday," and Packard replied, "Great news! Congrats Paul." Morris presented Epstein at a managing directors' meeting as a "success story," describing him as a "billionaire entrepreneur" and "one of the largest brokerage clients at JP Morgan." A 2014 list of the bank's fifty largest private-banking clients placed Epstein, through Southern Financial LLC, forty-seventh with 296 million dollars, the only client on the list covered by Morris. Morris has not been charged with any offense.³ A May 5, 2013 "approval email" from a senior executive reported that the head of anti-money-laundering compliance and the general counsel for the Americas, who chaired the reputational risk committee, did not think the relationship required reputational-risk review; the bank told the regulator it had no other record of that conversation, and the bank's Americas Reputational Risk Committee did not meet on the initial onboarding. When a compliance officer noted in October 2013 that one alleged co-conspirator had been named in a criminal case, a coordinator cleared the account by citing the approval email.¹

The relationship officially began on August 19, 2013, when Deutsche Bank opened brokerage accounts for Southern Trust Company Inc. and Southern Financial LLC, Epstein entities founded in the U.S. Virgin Islands.¹ Over the course of the relationship, Epstein, his entities, and his associates opened and funded more than 40 accounts at the bank.¹ The bank classified Epstein as "high-risk" and informally designated him an "Honorary PEP," or politically exposed person, because of his connections to prominent political figures.¹

The relationship had been publicly preceded by allegations against Epstein dating to 2005 and by his 2008 guilty plea to a state prostitution charge, after which press reports identified several alleged co-conspirators and described a modeling operation that brought young women, often from Eastern Europe, to the United States.¹

Suspicious Transactions and Overridden Warnings

As early as November 1, 2013, Epstein and his representatives used Deutsche Bank accounts to send wires to people who had been alleged to be co-conspirators in his past offenses, including at least 18 wires of 10,000 dollars or more to alleged co-conspirators identified in the consent order as Co-Conspirators 1, 2, and 3.¹ On January 24, 2014 the bank opened accounts for an Epstein trust named "The Butterfly Trust," whose beneficiaries included those alleged co-conspirators and a number of women with Eastern European surnames; Epstein described the beneficiaries to bank personnel as employees or friends.¹ Epstein used the Butterfly Trust and other accounts to send more than 120 wires totaling 2.65 million dollars to beneficiaries, for stated purposes such as hotel expenses, tuition, and rent, and made settlement payments to law firms exceeding 7 million dollars and additional legal-expense payments exceeding 6 million dollars.¹

Epstein's personal attorney made a total of 97 cash withdrawals from the bank's Park Avenue branch from 2013 to 2017, typically two to three times a month and each in the amount of 7,500 dollars, the bank's limit for third-party withdrawals, withdrawing in total more than 800,000 dollars on Epstein's behalf.¹ In May 2014 the attorney asked the bank how often cash could be withdrawn without triggering an alert, and in July 2017 he broke a withdrawal exceeding 10,000 dollars over two days; bank personnel found him credible and let him continue.¹ In a March 2017 exchange, a member of the transaction-monitoring team responded to an alert about payments to a Russian model and a Russian publicity agent by writing that "since this type of activity is normal for this client it is not deemed suspicious."¹

In January 2015 an anti-money-laundering officer escalated the relationship, citing a June 2014 appellate ruling reopening victims' challenge to Epstein's 2008 plea agreement and press reports of Epstein's relationships with "a prominent former U.S. politician and a member of a European royal family," whom the regulator did not name; a second officer's escalation memo stated that "[b]y 2011, 40 underage girls had come forward with testimony of Epstein sexually assaulting them" and that "Epstein managed to settle at least 17 lawsuits out of court." Later in January 2015 the senior executive and the relationship manager met Epstein at his New York home to ask about the allegations; the bank has no contemporaneous record of what was said.¹

The Americas Reputational Risk Committee met on January 30, 2015. Although bank policy required minutes, none exist; the same day a committee member emailed that the committee was "comfortable with things continuing" and that another member had "noted a number of sizable deals recently." The committee decided to "continue business as usual with Jeff Epstein" subject to three conditions, but those conditions were never communicated to all members of the Epstein relationship team or to the transaction-monitoring team, and a compliance officer read the requirement to flag "unusual" activity as meaning unusual compared with Epstein's own history, so that little changed; monitoring staff were told only to check online that the women involved were over 18. In July 2015 the committee's chairman approved higher trading limits for Epstein without a meeting after the senior executive "confirmed" there was no negative news. On January 4, 2016 an Epstein accountant asked to open an account for Gratitude America, Epstein's charity, and withdrew the request when the bank asked for an external due-diligence report.¹

A new relationship manager, identified by Wyden as Stewart Oldfield, took over by 2016 and was never told of the 2015 conditions. In May 2018 a compliance officer asked about wires to women with Eastern European surnames at a Russian bank; the accountant's written explanation was "SENT TO A FRIEND FOR TUITION FOR SCHOOL," and the relationship manager answered further questions by saying Epstein had "the flexibility to use any account they like." No further inquiry is recorded. Oldfield has not been charged with any offense.¹³ From 2013 to 2015 about 140 million dollars of Leon Black's payments to Epstein, wired from Black's accounts at Bank of America, went into Southern Trust Company accounts at Deutsche Bank, and a 2015 note from Deutsche Bank bankers recorded that another 20 million dollars from Black had "hit" Epstein's accounts.³⁴ The consent order found the bank's fundamental failure was that, although it properly classified Epstein as high-risk, it did little to scrutinize, inquire into, or block payments to named co-conspirators and to or on behalf of young women, or to ask why Epstein used on average more than 200,000 dollars per year in cash.¹

Records Produced to the Grand Jury

Deutsche Bank's Epstein records were produced to the U.S. Attorney's Office for the Southern District of New York under grand jury secrecy, stamped "DB-SDNY" and "CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)," and later appeared in the Justice Department's Epstein releases. A know-your-customer page headed "The 2013 Butterfly Trust" listed the trustee Erika Kellerhals, the Virgin Islands lawyer who had testified with Epstein at the 2012 hearing on Southern Trust's tax-incentive application, with the note "(Deutsche Bank already has on file)," and set out the trust's "Current Potential Beneficiaries," among them Epstein's assistant Lesley Groff, his pilot Lawrence Paul Visoski Jr. and his lawyer Darren Indyke, with other staff and associates, one of them listed at 301 East 66th Street in Manhattan; a "KYC Print" of July 15, 2019, nine days after Epstein's arrest, recorded him as the trust's grantor.⁵

Checks of Epstein's charity Gratitude America, Ltd., account address New York, New York 10154, were drawn on Deutsche Bank Trust Company Americas in 2016, including one dated August 1, 2016 for 37,500 dollars payable to Leon Botstein, president of Bard College, with the memo "3rd Quarterly Payment of 4."⁶ The consent order records that on January 4, 2016 an Epstein accountant withdrew a request to open an account for Gratitude America when the bank asked for an external due-diligence report.¹

In Leon Black's estate planning, a family-office checklist dated as of October 2, 2013 recorded "Preliminary meetings with Deutsche Bank taken" on financing against Black's art, and proposed a use agreement "between Heritage Trust and DB regarding use of art held by the Heritage Trust."⁷

In March 2019 Epstein's Southern Trust Company wired 2.4 million dollars to exercise warrants in the Israeli emergency-response company Carbyne, and Bank Leumi, where the investing partnership's general partner received the funds, asked for "a recommendation letter from the transferring bank of each limited partner." On March 12, 2019 Indyke wrote to Epstein that the lawyer handling the deal was "asking for a bank rec letter from the transferring bank which is DB. I have asked Rich to find out from Stewart Oldfield at DB with whom Rich has a decent relationship if that would even be possible at this point"; on March 14 he reported that "Stewart Oldfield is trying to find out what kind of letter he can get for us."⁸

The DFS Penalty and Victim Settlement

The New York Department of Financial Services issued its consent order on July 6, 2020, finding that Deutsche Bank conducted business in an unsafe and unsound manner in violation of New York Banking Law section 44 and failed to maintain an effective anti-money-laundering program in violation of 3 NYCRR section 116.2.¹ The order, brought under sections 39 and 44 of the Banking Law, also addressed the bank's correspondent relationships with FBME Bank and Danske Bank Estonia, through which it cleared more than 267 billion dollars in transactions and identified hundreds of suspicious transactions.¹ The order required Deutsche Bank to pay a penalty of 150 million dollars within ten business days, barred it from deducting the penalty for tax purposes or seeking insurance or indemnification for it, and credited the bank's cooperation and remediation. It did not appoint a new monitor but expanded the mandate of the independent monitor already in place under the January 30, 2017 consent order. The Department agreed to take no further action against the bank for the conduct described in the order, provided the bank complied with it, while reserving the right to act on conduct the bank had not disclosed. The order stated that the regulator left the question of what Epstein's cash was used for "to the criminal authorities." It was signed for the Department by Superintendent Linda Lacewell and for the bank by general counsel Karen Kuder.¹

The bank terminated the Epstein relationship after the Miami Herald published its November 2018 reporting on his 2008 plea deal, informing Epstein by letter on December 21, 2018 that it would no longer service his accounts.¹ After the bank decided to offboard the accounts, a relationship manager nonetheless drafted reference letters to two other financial institutions stating that he was "unaware of any problems relating to the operation or use" of the accounts.¹

After Epstein's July 2019 arrest, Deutsche Bank retroactively filed suspicious activity reports flagging more than 250 million dollars in wires, one of them covering 1,140 wires totaling 147 million dollars from 2013 to 2019, including payments to women in Russia and Eastern Europe and to modeling agencies; according to Wyden's report the bank had filed no contemporaneous report in almost six years. Wyden's staff asked the bank in June 2026 for the deposition transcript of Morris taken in the victims' suit, and the bank's lawyers declined.³

In May 2023 Deutsche Bank agreed to pay 75 million dollars to settle a federal lawsuit in New York brought by a survivor identified as Jane Doe, who sought class-action status on behalf of other victims and alleged that the bank knowingly benefited from Epstein's sex trafficking and chose profit over compliance with the law.² The plaintiffs were represented by Edwards Pottinger and Boies Schiller Flexner, and one firm characterized the deal as among the largest sex-trafficking settlements with a bank in U.S. history; a federal judge approved it in October 2023.²⁹