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from facilitating Epstein's sex abuse and sex trafficking. 
232. One issue regarding Epstein's sex trafficking arose in connection with 
the Bank's opening of a Global Markets account for Epstein. In January 2015, 
during the onboarding process for that account, a Deutsche Bank AML Compliance 
Officer ("AML Officer-11 identified recent developments in the press concerning 
Epstein, including: (1) a June 2014 federal appeals court ruling that some of 
Epstein's alleged victims would receive information supporting their challenge to 
Epstein's 2008 non-prosecution agreement, potentially reopening criminal cases for 
federal sex offenses against Epstein, and (2) additional allegations in the press 
regarding Epstein's relationships with a prominent former U.S. politician and a 
member of a European royal family. 
233. 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 Charles Packard, 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: (1) 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 
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opinion not to escalate to Rep Risk;" (2) the Head of AML Compliance was no 
longer at the Bank; and (3) there were new developments in Epstein's case that could 
lead to the reopening of his 2008 plea deal. 
234. 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 Patrick Harris, who agreed to escalate to the 
ARRC. In the email to Patrick Harris, AML Officer-2 noted that the communication 
underpinning the Approval 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." 
235. Later that month, on January 22, 2015, in preparation for the ARRC 
meeting, Charles Packard and Paul Morris met privately and in person with Epstein 
at his New York home. The private meeting was held in Epstein's Manhattan 
mansion. During the meeting, Packard asked Epstein about his involvement in sex 
trafficking. 
In response, Epstein allegedly "explained away" suspicious 
transactions, including large cash withdrawals and payments to Russian accounts 
that appeared suspicious in that they may have been indicators of sex trafficking and 
coercive commercial sex acts. Epstein's denials were not credible. 
236. During the meeting at Epstein's home, trafficking victims were in the 
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house, as they always were, and openly observable by Packard and Morris. 
237. Tellingly, and perhaps because of what Packard and Morris saw, 
Packard and Morris did not make any contemporaneous record of their meeting with 
Epstein. The reason they did not make a record of Epstein's denials was that any 
such record would have been utterly implausible. 
238. Through information and belief, other Deutsche Bank employees also 
met with Epstein personally outside the bank and made observations consistent with 
Epstein's daily sex trafficking activities, which included being surrounded by certain 
of his victims. 
239. Other than perfunctory, private meetings with Epstein to get their 
stories straight, Deutsche Bank did not take any other steps at the time to investigate 
the veracity of the allegations about Epstein being involved in sex abuse and sex 
trafficking. The reason Deutsche Bank did not take further steps to investigate the 
veracity of the allegations is because it knew that such investigation would only 
further confirm the allegations. 
240. On January 30, 2015, members of the ARRC, including Stuart Clarke, 
Chief Operating Officer for the Americas and General Manager of Deutsche Bank's 
New York branch, and Jan Ford, a Managing Director and Deutsche Bank Americas 
Head of Compliance and a member of the North America Executive Committee and 
the Global Compliance Executive Committee, met to discuss the Epstein 
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relationship. Despite the fact that Deutsche Bank's policies and procedures mandate 
that detailed minutes of such meetings be kept, Deutsche Bank did not make any 
record of this important meeting. Deutsche Bank decided not to make a record of 
this meeting because a record would have demonstrated that it knew, and was acting 
in reckless disregard of the fact, that Epstein was using his Deutsche Bank accounts 
to cause his victims, thorough means of force, fraud, and coercion, to be sexually 
abused and to engage in commercial sex acts. 
241. In a recent case before this Court, it was alleged that a confidential 
witness (identified only as "CW1") reported that the way this meeting was conducted 
flouted all of Deutsche Bank's rules about how such meetings should be handled. 
Specifically, the private meeting at Epstein's bar has been described as a "due 
diligence meeting" by Deutsche Bank. However, Deutsche Bank's own rules lay 
out how such diligence meetings are to be conducted when dealing with high risk 
clients. CW1 explained: "There are meant to be minutes taken, there is meant to be 
a thorough record of the meeting, allegations are meant to be put to the client in 
writing and the client is generally expected to have his lawyer or advisor, and often 
also his accountant, with him." Both sides are meant to sign off on the minutes of 
such meetings. Failing to abide by these regulations is a disciplinary offense at 
Deutsche Bank. According to CW1, however, neither Packard nor Monis were ever 
disciplined. See Karimi, Dkt. 37 at ¶ 87. 
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242. The reason that Deutsche Bank did not comply with its own rules 
described in the preceding paragraph is that it knew that compliance with the rules 
would create a paper trail about its awareness of its complicitly in Epstein's sex-
trafficking. 
243. Later that day, a member of the ARRC emailed Charles Packard to say, 
without explanation, that the committee was "comfortable with things continuing" 
with Epstein, and that another member of the committee had "noted a number of 
sizable deals recently." The reason that Deutsche Bank was "comfortable" with 
continuing its relationship with Epstein is because of the "sizeable deals" it was 
obtaining. The sizeable deals with Epstein were very valuable to Deutsche Bank 
and benefited Deutsche Bank financially. At that time (and earlier), Deutsche Bank 
knew that it was obtaining these "sizeable deals" only because it was willing to fund 
Epstein's sex-trafficking venture. 
7. Conditions on the Epstein Relationship Not Communicated to the 
Relationship Managers or the Relevant Transaction Monitoring 
Team. 
244. The following week, another member of the ARRC, Jan Ford, 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 Packard's "due diligence [bar] visit with him." 
Deutsche Bank knew, and was acting in reckless disregard of the fact, that Epstein's 
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usual business was the sexual abuse and coercive sex trafficking of young women 
and girls. 
245. That same email outlined three conditions that the ARRC placed on the 
relationship: (1) 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"; 
(2) 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]"; 
and (3) 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]." Deutsche Bank was aware that conditions such 
as these were necessary (although not sufficient) to prevent Epstein from using 
Deutsche Bank accounts in furtherance of sex abuse and coercive sex trafficking. 
246. Deutsche Bank had no intention of actually enforcing the conditions 
described in the previous paragraph on Epstein. Instead, the conditions were 
designed to create the illusion—i.e., a paper trail—that would make it appear that 
Deutsche Bank was closely monitoring Epstein when, in fact, it was allowing him 
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to use his multiple Deutsche Bank accounts for sex abuse and sex trafficking 
purposes. 
247. The three conditions were communicated to several senior Bank 
personnel who did not have day-to-day operational authority over the Epstein 
account. Deutsche Bank never communicated the conditions to those who could 
have enforced them—i.e., members of the Epstein relationship team. As a result, 
Epstein's relationship managers continued conducting business with Epstein in the 
same manner as they had before the ARRC meeting. The conditions thus became a 
dead letter—as Deutsche Bank had intended. 
248. 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 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 
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a Russian model and Russian publicity agent, stating, "[s]ince this type of activity is 
normal for this client it is not deemed suspicious." 
249. Instead of monitoring the accounts for all potential crimes and 
suspicious activity that could be implicated by Epstein's 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 internet 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 Deutsche Bank's furthering Epstein's sex abuse and 
his sex trafficking venture. 
8. Deutsche Bank Continued to Facilitate the Epstein Sex-Trafficking 
Venture for Years Despite Additional Red Flags. 
250. On July 21, 2015, Epstein requested that Deutsche Bank increase 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 
[Packard] last night to make sure he supports this and has heard nothing negative on 
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the client. [Packard] confirmed both." 
251. Again, without any due diligence and in complete disregard for the 
crimes Epstein was perpetrating and the reputational risks he posed, Deutsche Bank 
knowingly and intentionally allowed him to continue to employ Deutsche Bank's 
accounts to further his criminal activities. See Karimi, Dkt. 37 at ¶ 92. 
252. On January 4, 2016, an accountant representing Epstein (herein, 
"Accountant-1") requested that Deutsche Bank open a brokerage account for 
Gratitude America, 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 Epstein. In response to 
the request for additional information, Accountant-1 informed Deutsche Bank of 
Epstein's resignation from Gratitude America and withdrew the request to open the 
account. Thereafter, Deutsche Bank did not run a due diligence report on Epstein. 
253. Deutsche Bank was aware that the reason that Epstein was withdrawing 
his request to open the new account was to avoid a due diligence report. Deutsche 
Bank was aware that a due diligence report on Epstein would have documented that 
Epstein was using Deutsche Bank accounts to facilitate his sex abuse and sex-
trafficking venture. 
254. By April 2016, Paul Morris was replaced by another relationship 
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manager (herein, "Relationship Manager-2") to handle accounts associated with 
Epstein. Although Relationship Manager-2 had 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 Deutsche Bank of the three conditions the ARRC placed on the 
relationship after its February 2015 review. 
255. 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]hy is this client using this account to . . . pay school tuition?" 
Relationship Manager-2 replied "[g]enerally, Jeffrey has separate 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." 
256. The compliance officer did not ask any further follow-up questions, and 
the transaction was cleared. This transaction was one of many in which Epstein used 
his Deutsche Bank accounts to further his sex abuse and sex-trafficking venture. 
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Deutsche Bank did not inquire further about the transaction because it knew that 
doing so would only further expose its participation in and facilitation of Epstein's 
sex-trafficking venture. 
257. 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 women whom 
Epstein was sexually abusing and trafficking, including additional women with 
Eastern European surnames. 
9. Deutsche Bank Knew About Epstcin's Suspicious Cash Activity 
Throughout the Relationship 
258. Several of Epstein's employees or agents had authority to conduct 
transactions in the accounts on Epstein's behalf. One of them, Epstein's personal 
attorney (herein, "Attorney-1"), was active in withdrawing cash for Epstein. 
Attorney-1, on behalf of Epstein, made a total of 97 withdrawals from Deutsche 
Bank's Park Avenue (New York City) Branch from 2013 to 2017 from personal 
accounts belonging to Epstein. The transactions in question occurred roughly two 
to three times per month, all in the amount of $7,500 per withdrawal, Deutsche 
Bank's limit for third-party withdrawals (Le., withdrawals made by an authorized 
user who was not a primary account holder). When Deutsche Bank personnel asked 
Attorney-1 why Epstein needed cash, Attorney-1 replied Epstein used it for travel, 
tipping, and expenses. 
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259. 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." 
260. In May 2014, Attorney-1 inquired into how often he could withdraw 
cash on behalf of Epstein without triggering an alert. Around the same time, 
Relationship Coordinator-1 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?" 
261. 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 Deutsche 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. 
Nonetheless, Deutsche Bank permitted Attorney-1 to continue to withdraw cash 
from his own and Epstein's accounts. In 2018, just prior to Deutsche Bank's closing 
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of the Park Avenue Branch, which was located nearby Epstein's house, Attorney-1 
withdrew $100,000 in cash on behalf of Epstein. When later questioned why 
Attorney-1 withdrew these sums from Deutsche Bank, Attorney-1 reported that 
Epstein needed the funds for tipping and household expenses—an explanation that 
was not credible on its face. 
262. In total, in a roughly four-year period, Attorney-1 withdrew on 
Epstein's behalf more than $800,000 in cash from Epstein's personal accounts. 
Throughout the Epstein relationship, Deutsche Bank never sought or received any 
explanation for Epstein's substantial cash activity beyond the general travel, tipping, 
and expenses explanation provided by Attorney-1. The reason that Deutsche Bank 
never sought or received further information about Epstein's case activity is that it 
knew that truthful information would more directly expose Epstein's sex-trafficking 
venture. 
263. Attorney-1 also had accounts at Deutsche Bank. Attorney-1 withdrew 
substantial amounts of cash from his accounts and transferred money from Epstein 
controlled accounts to his accounts as payment or his participation in activities to 
further his sex abuse and his sex-trafficking scheme, including engaging in the crime 
of structuring outlined above. 
264. In light of all of these red flags, in addition to its actual knowledge that 
they were facilitating the Epstein sex-trafficking venture, Deutsche Bank was (at a 
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minimum) willfully blind and should have known that it was facilitating sex abuse 
and a sex-trafficking venture that was engaging in coercive sex trafficking in 
violation of 18 U.S.C. § 1591(a). 
265. In a recent case before this Court, it was alleged that a confidential 
witness (identified only as "CWI") reported that Epstein was retained as a client 
only after discussion at Deutsche Bank's Board level. See Karimi, Dkt. 86 at 6. 
266. In the same recent case before this Court, it was alleged that a 
confidential witness (identified only as "CW8") reported that "Deutsche Bank had a 
KYC [Know Your Customer] `special deal' for Epstein and other high-net-worth 
individuals. CW8 explained that such individuals were not required to submit to the 
normally required KYC documentation. 
Deutsche Bank gave them special 
exceptions because of the amount of business they generated." Id. at 7. With respect 
to Epstein, the reason for the special KYC deal was that applying standard KYC 
regulations would have more fully exposed Epstein's sex-trafficking venture. 
267. In the same recent case before this Court, a confidential witness 
("CW8") explained that "after Epstein was onboarded, decisions about whether to 
continue keeping him as a client were repeatedly escalated, including to Deutsche 
Bank's Reputational Risk Committee. `He would go up, get approved, go up, get 
approved,' CW8 said. CW8 noted that the people who sat on Deutsche Bank's 
Reputational Risk Committee were `primarily business-side people,' meaning they 
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were interested solely in making money for the Bank." Id. 
268. In the same case, another confidential witness ("CW1") explained that 
from the time of Epstein's onboarding, the relationship was classified by Deutsche 
Bank as "high-risk" and therefore should have been subject to enhanced due 
diligence. Instead, in an ironic twist, the Bank designated as an "Honorary PEP" 
(that is, an Honorary Politically Exposed Person). According to CW1, "there is no 
such thing as an honorary PEP. You are either a PEP or you aren't. I suspect they 
use this term to fudge things. Epstein was certainly very high risk .... But Deutsche 
Bank did not treat him as a high-risk client. I think the phrase `honorary PEP has 
been dreamt up to explain away why he wasn't treated as a high-risk client—whose 
accounts should have been constantly reviewed." Id., Dkt. 37 at ¶ 100. The reason 
Deutsche Bank did not constantly review Epstein's accounts is that it knew those 
accounts were being used as part of a sex-trafficking venture. 
10. 
Termination of the Epstein Banking Relationship 
269. In November 2018, the Miami Herald published a three-part 
journalistic report entitled Perversion of Justice, which rehashed old news stories 
about Jeffrey Epstein and his publicly known history of sexual abuse. While the 
series did not contain any new information, it resurfaced previously publicized 
information about Jeffrey Epstein's sexual abuse of women, now in a post-#MeToo 
world. 
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270. With the world now even more expansively talking about Epstein's 
long-known history for committing sex crimes, Deutsche Bank got nervous it would 
be exposed as the complicit banking partner of Epstein's operation. 
271. On December 21, 2018, after making millions on the banking 
relationship with Epstein, Deutsche Bank informed Epstein by letter that they would 
no longer be servicing his accounts. While Deutsche Bank stopped being Epstein's 
banker, it did not make a clean breast of things by disclosing its actions in support 
of the conspiracy to the authorities. Nor did it communicate its abandonment of its 
conspiring with Epstein and others in a manner reasonably calculated to reach 
Epstein's co-conspirators. 
272. While Deutsche Bank stopped being Epstein's banker, it continued to 
take subsequent actions to promote the venture and conspiracy. 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." 
273. Deutsche Bank fraudulently concealed its role in facilitating Epstein's 
sexual abuse and the sex-trafficking venture from the public until around July 2020. 
11. 
Deutsche Bank's Failure to File Suspicious Activity Reports 
274. Deutsche Bank also failed to timely file with the federal government 
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the required Suspicious Activity Reports (SARs) that financial institutions must file 
with the Financial Crimes Enforcement Network (FinCEN) whenever there is a 
suspected case of money laundering or fraud. Filing of these reports is required by 
the Bank Secrecy Act and related laws and regulations. These reports are tools that 
the federal government uses to detect and prosecute, among other illegal activities, 
sex trafficking in violation of the TWA. 
275. While Deutsche Bank was providing Epstein more than $200,000 in 
cash per year, it was required to file SARs about Epstein's suspicious and unusual 
cash transactions. 
276. Deutsche Bank's failure to filed SARs about Epstein's sex-trafficking 
venture, in spite of numerous red flags, was wrongful and purposeful. 
12. 
Conclusions Regarding the Epstein Accounts 
277. 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 transaction monitoring to detect suspicious or unlawful activity based on 
what the risk is. Deutsche Bank knowingly, intentionally, deliberately, and 
maliciously failed to do so with regard to its relationship with Epstein. 
278. After reviewing Deutsche Bank's relationship with Epstein, the New 
York Banking Regulators concluded that "although the Bank properly classified 
Epstein as high-risk, the Bank failed to scrutinize the activity in the accounts for the 
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kinds of activity that were obviously implicated by Epstein's past." 
279. Deutsche Bank was well aware not only that 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. 
280. Despite this knowledge, Deutsche 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 Epstein was using, on average, more 
than $200,000 per year in cash. 
281. Epstein used the $200,000 per year in cash to facilitate his sex abuse 
and his sex-trafficking venture. As the New York Banking Regulators concluded, 
the fact that the cash withdrawals "were suspicious should have been obvious to 
Bank personnel at various levels." In fact, Deutsche Bank personnel at various level 
did recognize that the transactions were being used by Epstein to facilitate his sex 
abuse and his sex-trafficking venture. 
282. Deutsche Bank's desire to maintain its profitable relationship with 
Epstein led it to deliberately avoid taking steps that would have documented its 
involvement in Epstein's sex-trafficking venture. Despite Epstein's prior criminal 
history, the initial onboarding of the first Epstein account was not reviewed by 
Deutsche 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 
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Email. That Approval Email was then relied upon, substantially without additional 
scrutiny, to open numerous other Epstein-related accounts. 
283. When the relationship was finally elevated to the full ARRC in early 
2015, no minutes were taken of that meeting, contrary to Deutsche Bank policy. 
Thereafter, the Committee continued the relationship based primarily on a brief, 
purported due diligence meeting between two front-office personnel and Epstein 
himself, the substance of which was also not reflected in writing. 
284. Moreover, the conditions imposed by the ARRC—conditions that, if 
followed, would have prevented many subsequent suspicious transactions—(1) were 
not transmitted to the majority of the relationship team; and (2) 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. As the New York Banking 
Regulators concluded, "Throughout the relationship, very few problematic 
transactions were ever questioned, and when they were, they were usually cleared 
without satisfactory explanation." 
285. To profiteer from the fees and referrals generated by Epstein, Deutsche 
Bank intentionally, continuously, and outrageously allowed Epstein to use its 
accounts to cover up old crimes and to facilitate new ones—a major compliance 
failure and reputational stain on the bank. See Karimi, Dkt. 37 at ¶ 42. 
286. Deutsche Bank should have filed SARs about Epstein's receipt of 
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hundreds of thousands of dollars in cash in suspicious circumstances. But it willfully 
failed to do so, because it knew that doing so would reveal the Epstein sex-trafficking 
venture and conspiracy. 
287. In and around the time that Deutsche Bank on-boarded Epstein, it 
became aware that it was joining in an on-going sex-trafficking venture and 
conspiracy. It was aware that the on-going venture and conspiracy had been 
operating in a similar manner back to (at least) 2005. Deutsche Bank choose to ratify 
the earlier acts of the venture and conspiracy and to act in furtherance of the venture 
and conspiracy. 
D. Deutsche Bank's Participation in the Epstein Sex-trafficking Venture 
Was Part of a Broader Pattern of Participating in Other Illegal and 
"High Risk, High Reward" Ventures. 
288. Deutsche Bank's intentional and outrageous participation in the Epstein 
sex abuse and sex-trafficking venture was not a "one off." To the contrary, its 
deliberate participation fits within a pattern and practice of Deutsche Bank profiting 
by undertaking illegal "high risk, high reward" clients. See generally, Karimi, Dkt. 
86 at 2 (recounting allegations that Deutsche Bank executives "routinely overruled 
compliance staff so that the Bank's wealth management business could commence 
or continue relationships with high-risk, ultra-rich clients, such as Russian oligarchs, 
the convicted sex trafficker Jeffrey Epstein, founders of terrorist organizations, 
persons associated with Mexican drug cartels, and people suspected of financing 
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