[GRADE A1 -- EFTA01416771 (Deutsche Bank internal document, Apr 15, 2019)]
A Deutsche Bank KYC periodic review dated April 15, 2019 -- three months before Epstein's arrest -- reveals the full trust architecture:
Neptune LLC (GCIS 487264):
Butterfly Trust (GCIS 486426):
[GRADE A1 -- EFTA01380999 (Deutsche Bank internal document, 2019)]
A companion KYC review requested Source of Wealth verification for Karyna Shuliak, noting: "She has US Driver's License (attached) and we found an old Employment Authorization Card (also attached) which shows her Country of Birth as Belarus." This establishes Shuliak as Belarusian-born, adding to her profile as documented in OS-05 (DNA kit registrar under alias "Jabor").
The review also requested confirmation of the "Primary Decision Maker for all three account holders" and whether there were "material changes" since the last review.
[v4.0 -- Pre-Arrest Asset Protection Sequence]
v4.0 maps the precise timeline of Deutsche Bank exit:
EFTA01425674 (Apr 15, 2019, 5 pages): Stewart Oldfield to Mayur Rathod: "These accounts (and all accounts under the southern financial relationship) are being exited. No need to do any of this work." CC: Sawant, Gillin, Barak, Advani. The KYC review (case 2075620) reveals joint account holder Karyna Shuliak, Neptune LLC (Epstein UBO, Beller/Indyke auth signors, Kahn manager), and Butterfly Trust (Epstein grantor, 8+ redacted beneficiaries). KYC team in Deutsche CIB Centre, Mumbai noted Shuliak's Country of Birth as Belarus.
EFTA01381015 (Jul 9, 2019, 3 days post-arrest): "Neptune, LLC has been changed to an Inactive Prospect in DB Force. All the Accounts associated to Neptune, LLC are now closed." Marked "CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)" and "DB-SDNY-0079716" -- grand jury material.
EFTA01399653 (Jul 11, 2019, 4 pages): Complete Butterfly Trust transaction dump -- 29 records across 6 categories (Business Wire, Cash Disbursement Check, Cash Disbursement Wire, Customer Research, Internal Transfer, Misc Instructions). Notable transactions:
Oldfield's graph footprint: 7,068 relationships -- one of the highest-density banker nodes. INVESTIGATED_IN "The F1 Network" dossier.
The Butterfly Trust structure reveals three critical connections to this investigation:
Shuliak as beneficiary: The same Karyna Shuliak who registered DNA kits (OS-05) is a named beneficiary of Epstein's Butterfly Trust. This creates a direct financial link between the DNA collection program's operational personnel and Epstein's trust architecture.
Kellerhals as trustee: Erika Kellerhals, who filed the Southern Trust Company EDC application (EFTA01100131) and received the DNA database certificate (EFTA01121673), is a trustee of the Butterfly Trust. She is the legal bridge between the USVI DNA database entity and Epstein's offshore trust.
Deutsche Bank KYC timing: The Apr 15, 2019 review was a routine periodic review, not a crisis response. However, the 30 Butterfly Trust fulltext documents include multiple Deutsche Bank transaction reports, indicating ongoing financial activity through this structure.
WHAT THIS SHOWS AND DOES NOT SHOW: Documents establish that DNA program personnel (Shuliak) and USVI entity lawyers (Kellerhals) were embedded in Epstein's trust structure as beneficiaries and trustees respectively. They do NOT show that trust funds were used for DNA program operations.