EFTA01346029 (Jul 25, 2017): Complete meeting notes (Quigley/Salit/Wang/Oldfield/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. 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."
Actions taken:
WHAT THIS SHOWS AND DOES NOT SHOW: This is the full text of the meeting the consent order references. Indyke LITERALLY ASKED THE TELLER if combining transactions would trigger reporting, then split them when told yes. This is conduct consistent with the statutory definition of structuring — not ambiguous, not accidental. "Mr. Epstein's household expenses" = cash withdrawals attributed to household expenses. DB confronted the client, filed a SAIF, but permitted the relationship to continue. The consent order states bank personnel found ATTORNEY-1 "credible" — these notes identify the specific personnel who made that determination. This does not establish that Indyke was charged with structuring or any other offense.
EFTA01346025 (Jul 24, 2017): Ying 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."
WHAT THIS SHOWS: The day before the confrontation meeting, DB AML explicitly used the word "structuring" and directed Oldfield to tell Indyke to stop. This is the pre-meeting that set up the July 25 confrontation documented above.