[Doc: NYDFS Consent Order]"Mr. Indyke routinely takes out cash from his account 42953707 and from Jeffrey Epstein's account 35269691 (he is the POA) on consecutive days. In addition, he has made comments to the teller asking if he does the transaction together would it require reporting?. After he was advised yes, he broke up the transactions into 2 consecutive days."
Told his pattern "gives the appearance of structuring to avoid CTR Reporting." Indyke claimed "not his intention to structure" — needs cash "for his business as well as for Mr. Epstein's household expenses."
[Doc: [EFTA01346029](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01346029.pdf) | Ref: Jul 25, 2017]
April 26-27, 2017: Indyke explicitly asked tellers about CTR thresholds, stated he wanted to "avoid paperwork and going over his limit," split transactions across days after being told combining would trigger reporting. July 20-21, 2016: repeat of same behavior, predating confrontation by a full year.
Account balances: Jeffrey Epstein $3.4M; Darren K. Indyke PLLC (#42953707) $414K.
[Doc: [EFTA01345993](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01345993.pdf) | Ref: SAR full text]
Wang to Quigley: "We had a meeting with Wayne Salit and Relationship Manager Stewart Oldfield today 7/24/17 regarding Mr. Indyke's cash activity and advised Mr. Oldfield to advise his client to cease structuring activity."
[Doc: [EFTA01346025](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01346025.pdf) | Ref: Jul 24, 2017]
Quigley (Jun 23, 2017): "I don't see any Cash Alerts for this. Am I missing them." Then: "For CustCash, is his dollar value too low to hit? We might want to revisit this rule if he is not hitting." And: "Did we file a SAIF on him recently? I think we need to file."
Wang: "It looks like the transactions (7.5k and 6.6k) have not been uploaded into prime yet."
[Doc: [EFTA01346001](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01346001.pdf) / [EFTA01346003](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01346003.pdf) / [EFTA01346005](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01346005.pdf) / [EFTA01346008](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01346008.pdf) | Ref: Jun 23, 2017]
Gillin: "This is regarding account [redacted] (Jeffrey E. Epstein). Darren Indyke had full POA on this account — see attached. He is a familiar face." RE: "Large withdrawal."
[Doc: [EFTA01345692](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01345692.pdf) / [EFTA01345700](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01345700.pdf) | Ref: Sep 18, 2017]
Epstein's custody account held 88,000 EUR (~$122K). DB arranged for Indyke to physically pick up 15,000 EUR in cash from the branch, navigating the 7,500 EUR/USD per-day withdrawal limit. Morris: "I spoke with Paul and we have a few more questions."
[Doc: [EFTA01345572](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01345572.pdf) / [EFTA01345629](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01345629.pdf) | Ref: May 8-9, 2014]
Madiar (AVP/Assistant Branch Manager, 345 Park) to Wang/Quigley: "Darren Indyke transaction. Darren has not come in, to cash the $4000.00. I will advise, once he does." Branch staff actively tracking Indyke's pickup patterns.
[Doc: [EFTA01345959](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01345959.pdf) | Ref: Jul 21, 2016]
Morris re LB ISDA: "I spoke with him, he knows we need some financial info on lb before we can get him a draft ISDA." Indyke: "Good morning, Paul. Not sure what you are asking for. Please clarify." Establishes Indyke as conduit between Morris and Leon Black for derivatives documentation.
[Doc: [EFTA01468614](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01468614.pdf) | Ref: Apr 30, 2014]
ATTORNEY-1 "inquired into how often he could withdraw cash on behalf of Mr. Epstein without triggering an alert." RC-1 emailed branch manager: "asked how often they could come in to withdraw cash without creating some sort of alert... Is it once a week? Twice a week? Once every other week?"
Final withdrawal: "just prior to the Bank's closing of the Park Avenue Branch... ATTORNEY-1 withdrew $100,000.00 in cash on behalf of Mr. Epstein." Explanation: "needed the funds for tipping and household expenses."
[Doc: NYDFS Consent Order | Ref: §§ on ATTORNEY-1]
¶69: "Structured hundreds of Epstein's bank accounts, created and administered dozens of corporate entities, regularly made large cash withdrawals."
¶3: 4,725+ wire transfers exceeding $1B (2003-2019).
¶23: "In 2019, Darren Indyke and Richard Kahn instilled even more fear in Doe when they attempted to contact her through other associates of Epstein, including Lesley Groff and Bella Klein."
¶48: Used attorney-client privilege to shield trafficking operation communications.
¶74: "Structured withdrawals of cash in amounts that didn't trigger federal reporting."
[Doc: BNY Amended Complaint 1:25-cv-08525-JSR | Ref: ¶3, ¶23, ¶48, ¶69, ¶74]
[Doc: [EFTA0128229](https://www.justice.gov/epstein/files/DataSet%209/EFTA0128229.pdf)7][Doc: [EFTA0128207](https://www.justice.gov/epstein/files/DataSet%209/EFTA0128207.pdf)0][Doc: Black Book | Ref: p73]Rodriguez requested $1K→$12K daily limit increase (Dec 22, 2017). Wang: "Mr. Epstein's debit card has already been upgraded to $12,000 without our approval. Why are we being notified only now?" Quigley — who identified structuring 5 months earlier — approved the product side. A second structuring-adjacent channel operating outside AML oversight.
[Doc: [EFTA01346059](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01346059.pdf)/062/063 | Ref: Dec 2017];[Doc: [EFTA01346044](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01346044.pdf)/045/046 | Ref: Mar 2018]
LSJE LLC — KYC stated: "Established for purposes of maintaining payroll and maintenance related expenses of Mr. Epstein's private residence. No business purpose." Signatories: JEE + Indyke. Sent international wire to Minsk Transit Bank, Belarus, 4 months before arrest. A "no business purpose" household payroll entity wiring to Belarus.
[Doc: [EFTA01288310](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01288310.pdf) | Ref: Mar 2019];[Doc: [EFTA01472269](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01472269.pdf) | Ref: KYC]
[Doc: [EFTA0138795](https://www.justice.gov/epstein/files/DataSet%209/EFTA0138795.pdf)9]Full chain: Nili Priell Barak (Barak's wife) → Epstein (Mar 6): transfer info for "Co. for the benefit of the Public," signed "EB." Epstein → Nili: "name on the account? I was going to wait until i saw ehud in paris." Nili provided: Achrayut Leumit Ltd., Bank Leumi, Branch 666, Ramat Gan, SWIFT LUMIILITXXX. Epstein → Kahn (Mar 12-13, forwarded chain). Kahn: "please advise on amount to send." $40,000 wired Mar 16 from HBRK Associates (acct #42953715).
DB AML flagged (Case 141374). Kahn's answers: "Contributions for public policy organization in Israel" / "Friend" / "Public Policy Org." No escalation. Post-conviction payment from Epstein's executor to former Israeli PM's political entity.
[Doc: [EFTA02350723](https://www.justice.gov/epstein/files/DataSet%2011/EFTA02350723.pdf), [EFTA02657336](https://www.justice.gov/epstein/files/DataSet%2011/EFTA02657336.pdf), [EFTA02386927](https://www.justice.gov/epstein/files/DataSet%2011/EFTA02386927.pdf), [EFTA02657848](https://www.justice.gov/epstein/files/DataSet%2011/EFTA02657848.pdf), [EFTA02658178](https://www.justice.gov/epstein/files/DataSet%2011/EFTA02658178.pdf) | Ref: Mar 6-13, 2017];[Doc: [EFTA01297175](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01297175.pdf) | Ref: bank statement];[Doc: [EFTA01364033](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01364033.pdf), [EFTA01409043](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01409043.pdf), [EFTA01432431](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01432431.pdf) | Ref: compliance chain][GRADE A1 — primary emails + bank records]
[Doc: [EFTA0142654](https://www.justice.gov/epstein/files/DataSet%209/EFTA0142654.pdf)7]