[GRADE A2 — Internal DB compliance emails/meeting notes (EFTA production)]
EFTA01346010, EFTA01346029 (Jun-Jul 2017): DB AML identified a history of cash structuring activity:
EFTA01346010 (Jul 19, 2017): Ying Wang to Oldfield/Liconte/Quigley/Salit:
"DB AML has identified a history of cash structuring activity in accounts for Darren K. Indyke PLLC and/or Jeffrey Epstein. There has been three instances since July 2016 in which client Darren K. Indyke has performed multiple cash withdrawals o[ver threshold]"
EFTA01346029 (Jul 25, 2017): Meeting notes — Quigley, Salit, Wang, Oldfield, and Indyke (client):
"Transaction Monitoring recently filed a SAIF regarding the appearance of Structuring involving Darren Indyke. Mr. Indyke routinely takes out cash from his account 42953707 and from Jeffrey Epstein's account 35269691 (he is the POA) on consecutive days."
WHAT THIS SHOWS AND DOES NOT SHOW: Indyke was withdrawing cash from both his own Darren K. Indyke PLLC account (42953707) and Epstein's account (35269691) as Power of Attorney on consecutive days — conduct consistent with the statutory definition of structuring across two accounts to avoid the $10K CTR threshold. A meeting on July 25, 2017 — attended by Quigley, Salit, Wang, Oldfield, and Indyke himself — directly confronted Indyke about this pattern. This is the same structuring confrontation referenced in the NYDFS consent order, now with specific names of the DB personnel who challenged Indyke: Cherie Quigley (AML Transaction Monitoring), Wayne Salit (Compliance), Ying-A Wang (AML analyst), and Stewart Oldfield (RM-2). The consent order states Indyke "represented that he had not intended to structure" and "Bank personnel found ATTORNEY-1 credible and permitted him to continue." These documents identify which bank personnel made that determination.
[GRADE A2 — Internal DB compliance records (EFTA production)]
EFTA01346010 confirms Indyke maintained a personal account at Deutsche Bank under the entity name Darren K. Indyke PLLC (account #42953707), separate from his role as authorized signer/POA on Epstein's accounts. The structuring investigation revealed Indyke was using both his personal PLLC account and Epstein's personal account for consecutive-day cash withdrawals, totaling $22K+ without CTR filing (EFTA01346001 — Quigley: "3 consecutive days of cash withdrawals totaling over $22K and no CTR").