[GRADE A2 — Internal DB email (EFTA production) — Packard to Morris, cc Harris]
EFTA01344266 (May 14, 2013) + 5 copies (EFTA01299305, 01299311, 01299317, 01299333, 01299405):
Chip Packard to Paul Morris, cc Patrick Harris:
"Spoke with both Caruso and Polizzotto. Neither suggest this requires rep risk and we can move ahead so long as nothing further is identified through KYC and AML client adoption."
Multiple copies exist (6 EFTAs). Morris forwarded to himself with "fyi." Amanda Kirby forwarded to Armen Brash Aug 2013.
WHAT THIS SHOWS AND DOES NOT SHOW: This is the Approval Email referenced throughout the NYDFS consent order. Caruso and Polizzotto are now identified as the DB Legal/Reputational Risk officers who told Packard that Epstein did not require rep risk escalation. Patrick Harris (EXECUTIVE-2 candidate) was cc'd on the original — placing him in the Epstein approval chain from Day 1. The consent order notes the bank "has no other record of this communication" between Packard and these officers. The 6 copies across the EFTA production confirm this email was widely distributed and retained. This documents the approval decision but does not establish that Packard, Caruso, or Polizzotto acted improperly — they may have conducted a legitimate assessment and concluded rep risk was not triggered.
These are the individuals the consent order refers to when it states the Approval Email referenced "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." Caruso and Polizzotto are now named.