Money laundering isn’t inherently comical. Jeffrey Epstein, may he rot in hell, isn’t funny at all. And yet, the consent order laying out exactly why Deutsche Bank just agreed to pay a $150 million fine to the New York State Department of Financial Services is HILARIOUS.
No, wait, come back! For reals, this shit is nuts.
It all started in 2013 when JP Morgan told Epstein to take his multiple hundreds of millions of dollars and hit the road, Jeff. He’d pled guilty in 2008 to sex crimes involving an underage girl in Florida, and in 2009 details of his settlements with dozens of accusers appeared in the press, but it only took five years for JP Morgan to decide that the financier represented a reputational risk to the bank that agreed to hold his money. Which sounds bad, but then Deutsche Bank said HOLD MY BEER.
In 2013 Epstein’s private money manager from JP Morgan joined DB and promised that if they took on her former client, he would bring $100 to $300 million in assets and net the firm between $2 and $4 million in fees every year. KA CHING!
Oh, sure, they thought about the risks. But, you know, not all that hard.
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 [Know Your Customer] and AML [Anti-Money Laundering] 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.
Because what even is due diligence?
By November 2013, Epstein was already using his DB accounts to send money to people who had been publicly named as co-conspirators in the Florida indictment and public reporting, and in January 2014 he opened a checking and money market account for a trust called "The Butterfly Trust."