[GRADE A1 — NYDFS Consent Order (regulatory enforcement action)]
- Proposed Epstein as a client — "suggested to senior management in Deutsche Bank that Mr. Epstein was a potential client who could generate millions of dollars of revenue as well as leads for other lucrative clients"
- Estimated the revenue — "estimated flows of $100-300 [million] overtime with revenue of $2-4 million annually over time"
- Proposed entity account structure — All accounts for "entities" affiliated with Epstein, "not personal accounts"
- Co-prepared the onboarding — Sent the onboarding memorandum (prepared by RC-1) to EXECUTIVE-1 and EXECUTIVE-2
- Met Epstein at his New York home — January 22, 2015, with EXECUTIVE-1 (Chip Packard). No contemporaneous records of this meeting.
- Served as primary RM from onboarding through April 2016
WHAT THIS SHOWS AND DOES NOT SHOW: The consent order establishes that Morris initiated the Epstein relationship at DB, estimated its revenue potential, proposed its account structure, and attended a meeting at Epstein's home during the ARRC review. It does not establish that Morris knew DB accounts were being used to facilitate criminal activity. The consent order penalized Deutsche Bank as an institution; no individual was charged.