Brash (AML Business Risk, 60 Wall St) to Lightbody AND Franklin (cc Kirby): "The above named KYC has been sent to your queue; this is a high risk relationship due to the negative media and criminal convictions for Mr. Epstein. Please see previous KYC 01082293 for escalation and details."
Kirby replied asking about submitting more business accounts. Franklin signed the AML Compliance approval six days later (Sep 10, 2013).
[Doc: [EFTA01360710](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01360710.pdf) | Ref: Sep 4, 2013]
Sep 5, 2013: Rejects Jeepers Inc KYC — "Please provide us with a certificate of Good standing."
[Doc: [EFTA0136099](https://www.justice.gov/epstein/files/DataSet%209/EFTA0136099.pdf)5]
Feb 25, 2014: "Did I miss it? KYC 1121718 does not list Mr. Beller as a signer on Mr. Epstein's accounts."[Doc: [EFTA0136069](https://www.justice.gov/epstein/files/DataSet%209/EFTA0136069.pdf)0]
Feb 27, 2014: "In conjunction with our review of KYC 1195100, I saw that the letter to add Mr. Indyke stated that he should be added 'on all accounts associated with the Southern Financial Relationship'. How did you determine that the Southern Financial Relationship included Mr. Epstein's personal accounts and those for Southern Trust?"[Doc: [EFTA0135790](https://www.justice.gov/epstein/files/DataSet%209/EFTA0135790.pdf)6]
Mar 3, 2014: Recommends Epstein send specific account instructions or Legal sign-off.[Doc: [EFTA0136068](https://www.justice.gov/epstein/files/DataSet%209/EFTA0136068.pdf)3]
Mar 4, 2014: Rejects KYCs outright: "we would [not approve] a KYC where Mr. Epstein had given instructions to add Mr. Indyke to [redacted] account on the basis that Mr. Epstein does not have authority over [her] account... Please provide us with more specific instructions... or provide us with [an] email from Legal."[Doc: [EFTA0136068](https://www.justice.gov/epstein/files/DataSet%209/EFTA0136068.pdf)2]
Mar 14, 2014: (Gwen Hill) rejects Jeepers Inc KYC — signers don't match corporate resolution.[Doc: [EFTA0135787](https://www.justice.gov/epstein/files/DataSet%209/EFTA0135787.pdf)3]
"I agree with your assessment that Mr. Epstein should be treated as a RCA. Hence, all clients where he is UBO or has a significant controlling role should be automatically risk rated 'High'."
Hill identified Epstein was never formally escalated as PEP despite Prince Andrew/Clinton relationships. Franklin: "Although the PEP status was factored into the prior risk calculator, the client was never formally escalated as a PEP."
[Doc: [EFTA01299337](https://www.justice.gov/epstein/files/DataSet%2010/EFTA01299337.pdf) | Ref: Oct 19, 2018]
"not a direct approval by [AML/Legal]; it's a statement by a front office MD about his conversation with them and their alleged opinion not to escalate to Rep Risk."
Person referenced was "no longer at the Bank." Also noted "new developments in Epstein's case that could lead to the reopening of his 2008 conviction" — June 2014 federal appeals court ruling granting victims access to plea bargain details, plus allegations regarding "a prominent former U.S. politician and a member of a European royal family."
[Doc: NYDFS Consent Order | Ref: AML-1 Jan 2015]