[GRADE A1 -- EFTA01374407, EFTA01373974, EFTA01375517, EFTA01374232, EFTA01399982 (DB internal, SDNY production)]
Deutsche Bank's automated Risk Detection and Classification (RDC) system flagged Richard Kahn on three separate occasions between 2013 and 2016. Each time, the alerts were cleared as "false positive." The pattern of clearance reveals not a series of coincidences, but a systematic compliance override in which Kahn himself provided the material used to suppress the bank's own risk flags.
November 2013 (EFTA01375517): Michael Vila (AML Compliance, DB Jacksonville) cleared an RDC alert on Kahn, stating the alert was "a false positive" based on "an email dated 10/31/2013 that the business received from Mr. Kahn attesting that he has not been barred from NYSE Arca." Kahn's own self-attestation was the basis for clearing the alert.
December 2014 (EFTA01374232): Syed-Anzar Ahmed (DBOI Bangalore) cleared three separate RDC alerts on Kahn -- all dismissed as "False Positive. Mismatch Individuals. NO ESCALATION REQUIRED."
October 2016 (EFTA01399982): Cynthia Rodriguez (DB Trust Company Americas) requested clearance for Kahn, who had triggered hits on NYSE disciplinary actions, Florida OFR final orders, the Colorado sex offender list, and an Illinois drug conspiracy warrant. Rodriguez cleared all four on the basis of date-of-birth mismatch.
December 2014 -- THE SMOKING GUN (EFTA01374407): Dmitri Saks (AML Compliance Officer) completed an Enhanced Due Diligence report on Southern Financial LLC. The report states: "Epstein is a registered sex offender. Since 2005, there have been multiple allegations against Epstein regarding sexual assault of minors. In 2008, he was convicted and received an 18-month sentence for soliciting an underage girl for prostitution. By 2011, 40 underage girls had come forward." In the same document, the report notes: "RDC also produced a number of false positive alerts on a control person, Richard Kahn."
Saks approved the account as "High Risk" and recommended "escalating this case to the Americas Reputational Risk Committee for review." Kahn is named as "inquiry capacity" signatory on the Southern Financial accounts (EFTA01344265).
January 2015 (EFTA01420399): Wayne Salit conditionally approved the EDD, stating "negative information was identified regarding Jeffrey Epstein, the sole UBO" and recommending "the entire DB relationship with Mr. Epstein" be presented to the Americas Reputational Risk Committee.
February 2015 (EFTA01461132): Jan Ford (Managing Director, Head of Compliance Americas) confirmed: "We agreed last week at RRC to continue business as usual with Jeff Epstein based upon Chip Packard's due diligence visit with him."
[GRADE A1 -- EFTA01478160 (DB internal, April 2016)]
On April 25, 2016, Melinda Roy (DB Trust Company Americas) emailed Bella Klein, CC: Richard Kahn, Paul Morris, regarding wires flagged as "high risk" due to country of destination: $300,000 to LSJE LLC at FirstBank Puerto Rico and $150,000 to Zorro Development Corporation. Roy asked: Who are the beneficiaries? What is the purpose? Will we expect future transactions?
This is not constructive knowledge. Kahn was directly emailed about high-risk wire alerts on Epstein's accounts.
[GRADE A1 -- DB internal, January 2016]
Daniel Sabba (Key Client Partners) wrote to Todd Stevens and Wayne Salit: "Jeffrey Epstein's CFO (Rich Kahn) has requested the opening of a new account on Tuesday... Per the determination made by the [Reputational Risk] committee, this would require the account opening to be brought to reputational risk committee for approval."
DB's own business team classified Kahn not as an external bookkeeper, but as the chief financial officer of the enterprise.
[GRADE A1 -- DB internal, January-February 2015]
Troy Williams (Credit Risk Management) flagged "recent press about Mr. Epstein" with an attached WSJ article about Prince Andrew. Daniel Sabba responded: "Renee -- please liaise with Richard Kahn for communication regarding this matter. I have CCed Rich here."
Separately, Darren Indyke emailed Amanda Kirby CC: Richard Kahn about Butterfly Trust trustee changes. Kirby forwarded to Paul Morris: "With all the recent press there will be alerts raised on JE's and this will go to High Risk for approval."
[GRADE A1 -- EFTA01265973 (Schwab AML internal, July 2019)] [V2.0]
On July 8, 2019 -- two days after Epstein's arrest -- Charles Schwab opened AML Case CA11517. The referral identifies five subjects: Jeffrey Epstein, Southern Trust Company Inc., Southern Financial LLC, Southern Country International Ltd, and Richard Kahn. The investigation note states: "RICHARD KAHN (46 years old) established a relationship with Schwab in April 2019 maintaining three active accounts for which he maintains an agent role granting him the authority to conduct activity within the three corporate accounts."
The document reveals Kahn moved Epstein's brokerage relationships to Schwab in April/May 2019 -- the same months he was closing 6 DB accounts. Notably, it also records: "COATUE ENTERPRISES LLC -- Actively registered in the state of NY with agent listed as HBRK ASSOCIATES INC. (KAHN'S company)."
The referral documents a $12.7M wire attempt to Morocco (Marc Leon / Kensington Morocco) on June 26, 2019, followed by a $14.95M second attempt on July 4, 2019 -- both wires signed by Kahn and Epstein, both ultimately canceled. Schwab filed a SAR.
WHAT THIS SHOWS AND DOES NOT SHOW: The documents establish that (a) Kahn was named in the EDD that describes Epstein as a registered sex offender with "40 underage girls," (b) Kahn was directly CC'd on high-risk wire alerts, (c) Kahn was designated as DB's client contact during press-related KYC updates, (d) Kahn continued operating the accounts for 4+ years after High Risk designation, and (e) Kahn simultaneously opened new brokerage accounts at Schwab while closing DB accounts, suggesting migration rather than cessation. The documents do NOT show that Kahn personally opened and read the EDD. However, the direct email notification (EFTA01478160) eliminates the delivery gap.