[GRADE A1 — NYDFS Consent Order + Wyden Senate Memo]
| Activity | Amount | Period | Source |
|---|---|---|---|
| Cash withdrawals (97 transactions × ~$7,500) | $800,000+ | 2013-2017 | NYDFS consent order |
| Final cash withdrawal (branch closing) | $100,000 | 2018 | NYDFS consent order |
| Subtotal (DB period) | $900,000+ | 2013-2018 |
WHAT THIS SHOWS AND DOES NOT SHOW: The financial record documents over $900,000 in cash withdrawals through techniques that the consent order characterizes as raising structuring concerns. The bank confronted Indyke about the pattern and accepted his explanation. The consent order does not state that these withdrawals funded criminal activity — it states they were "suspicious" and inadequately investigated by the bank. The destination of the cash is unknown in the available record.