[GRADE A1 — NYDFS Consent Order (regulatory enforcement action)]
The consent order attributes the following actions to RELATIONSHIP COORDINATOR-1:
- April 2013: The consent order states RC-1 "prepared a memorandum" for RM-1 to send to EXECUTIVE-1 and EXECUTIVE-2. The memo documented Epstein's plea deal, prison sentence, and 17 civil settlements.
- October 2013: The consent order states a compliance officer flagged CO-CONSPIRATOR-2 (Sarah Kellen) as an alleged co-conspirator among Butterfly Trust beneficiaries. RC-1 confirmed that CO-CONSPIRATOR-2 "was accused as a co-conspirator in a case but was never brought to trial nor ever convicted."
- May 2014: The consent order states RC-1 emailed the branch manager about ATTORNEY-1's inquiry: "asked how often they could come in to withdraw cash without creating some sort of alert... Is it once a week? Twice a week? Once every other week?"
- RC-1 "has since represented that she understood ATTORNEY-1's inquiry related to ATTORNEY-1's desire to withdraw more than the $7,500 limit for third-party withdrawals, and not to CTR filing requirements."
WHAT THIS SHOWS AND DOES NOT SHOW: The consent order establishes that RC-1 documented Epstein's criminal history in the onboarding memo, cleared a known co-conspirator as a trust beneficiary, and relayed a question about alert avoidance. RC-1's later representation that the cash inquiry was about withdrawal limits (not CTR avoidance) is noted by the consent order without endorsement or rejection. The consent order does not state that RC-1 acted improperly — the regulatory finding is against Deutsche Bank's systems and controls, not against individual judgment calls.