[GRADE A1 — NYDFS Consent Order against Deutsche Bank (July 6, 2020) (regulatory enforcement action)]
The New York Department of Financial Services consent order against Deutsche Bank provides the most granular view of how co-conspirators were embedded in Epstein's financial infrastructure. The consent order identifies three co-conspirators by designation rather than name: CO-CONSPIRATOR-1, CO-CONSPIRATOR-2, and CO-CONSPIRATOR-3.
The Butterfly Trust was opened at Deutsche Bank in November 2013, two months after Epstein was formally onboarded as a client (August 19, 2013 — five years after his sex crime conviction). The consent order documents that compliance personnel flagged the co-conspirators as trust beneficiaries at the time the account was opened. Despite this flagging, the account was maintained.
Key financial flows documented in the consent order:
| Category | Amount | Detail |
|---|---|---|
| Wires to trust beneficiaries including co-conspirators | $2,650,000 | Butterfly Trust disbursements |
| Legal expenses for Epstein and co-conspirators | $6,000,000 | Paid through Deutsche Bank accounts |
| Deutsche Bank regulatory penalty | $150,000,000 | NYDFS consent order |
The consent order attributes the phrase "recruited underage girls" to co-conspirators — this language appears in the regulatory document as a finding of fact by NYDFS, not merely as an allegation.
The consent order documents that Deutsche Bank compliance personnel identified the co-conspirators as trust beneficiaries and flagged the arrangement, yet the bank proceeded with the account. This compliance failure chain — identification, flagging, and continued service despite the flag — is the regulatory basis for the $150 million penalty.
The Butterfly Trust structure reveals how the inner circle was financially embedded in Epstein's wealth management architecture. The co-conspirators were not merely paid for services — they were named beneficiaries of a trust instrument, a legal structure that implies long-term financial dependency. The $2.65 million in documented wires to trust beneficiaries and the $6 million in legal expenses indicate that Epstein funded not only the co-conspirators' living expenses but their legal defense.
The CO-CONSPIRATOR-1/2/3 designations in the NYDFS consent order have not been officially mapped to specific individuals in the public record. The identities behind these designations remain a partially answered question (see UNANSWERED QUESTIONS below).
WHAT THIS SHOWS AND DOES NOT SHOW: The NYDFS consent order documents that co-conspirators were Butterfly Trust beneficiaries, that $2.65 million flowed to trust beneficiaries, and that $6 million in legal expenses were paid for Epstein and co-conspirators through Deutsche Bank accounts. This establishes financial dependency between the co-conspirators and Epstein's wealth infrastructure. It does not identify which specific individuals are designated CO-CONSPIRATOR-1/2/3, and the financial dependency documented here does not, standing alone, establish the criminal conduct of any specific co-conspirator — it establishes that Epstein's financial structure was designed to support them.
The Butterfly Trust exists in the Neo4j graph as a Person node (not an Organization), connected to CARDOON FINANCE S.A. via an ICIJ_LINKED_TO relationship and MENTIONED_IN document EFTA00029805. Approximately 25 LINKED_TO_OFFSHORE connections exist but are predominantly false positives — geographic addresses in Malta, Singapore, and San Jose that the offshore data importer's fuzzy matching incorrectly linked to the "Butterfly" string. The CARDOON FINANCE S.A. connection is the only confirmed institutional link, sourced from ICIJ Panama Papers data.
The Butterfly Trust's presence as a Person node rather than an Organization node is a data quality artifact — the entity extraction pipeline classified it as a person name rather than a legal entity. This misclassification does not affect the documentary content but complicates automated queries.