[GRADE A1 — NYDFS Consent Order (regulatory enforcement action)]
The consent order states EXECUTIVE-1 "sent an email to RELATIONSHIP MANAGER-1 which read 'spoke with [the Head of AML Compliance for Deutsche Bank Americas and the then-General Counsel for Deutsche Bank Americas, who at that time served as chair of the Bank's Americas Reputational Risk Committee]. Neither suggest [that the Epstein relationship] requires rep risk and we can move ahead so long as nothing further is identified through KYC and AML client adoptions.'"
The consent order further states: "The Bank has represented to the Department that it has no other record of this communication between EXECUTIVE-1 and the other officers."
The consent order states EXECUTIVE-1 and RM-1 (Paul Morris) "met in person with Mr. Epstein at his New York home." During the meeting, the consent order states EXECUTIVE-1 "asked Mr. Epstein about the veracity of the recent allegations and appeared to be satisfied by Mr. Epstein's response." The consent order states the bank "is not in possession of contemporaneous records reflecting the substance of EXECUTIVE-1's meeting with Epstein and is not aware of any other steps taken at the time to investigate the veracity of the allegations beyond speaking with Mr. Epstein."
The consent order states that when the ARRC chairman asked about Epstein's trading limit increase, EXECUTIVE-1 "confirmed both" that they supported the request and had "heard nothing negative on the client."