[GRADE A1 — NYDFS Consent Order]
The Approval Email is the structural keystone of the entire Epstein-DB relationship. The consent order documents it was:
The consent order states this email was based on a conversation for which "the Bank has represented to the Department that it has no other record." The Head of AML Compliance referenced in the email was, per the consent order, "no longer at the Bank" by January 2015 — meaning the person whose alleged approval underwrote the relationship could not be asked to confirm it.
Now identified as "Chip Packard Approval - Jeffrey Epstein.pdf" — a document DB compliance filed, circulated, and relied upon for five years.
WHAT THIS SHOWS AND DOES NOT SHOW: The consent order establishes the Approval Email as the single point of authorization for a relationship that generated 40+ accounts and processed millions in suspicious transactions. The absence of corroborating records for the underlying conversation is a regulatory finding, not an accusation of fabrication. The NYDFS found the bank's reliance on this email to be a "major compliance failure" — this is a finding about institutional controls, not individual culpability.