[GRADE A2 — Internal DB AML email (EFTA production) — 6 copies across KYC cases]
EFTA01299233-318 (×6 copies): Andrew J. Kisz (AML Compliance Officer, Jacksonville) to Amanda Kirby:
"AML Compliance has reviewed the RDC and PCR alerts dated 5/28/2013 pertaining to our prospective client, Jeffrey Epstein. The RDC Alerts are positive matches for our prospect as it pertains to negative information based on reputation. However, AML Compliance clears these alerts based on the attached email approval from Chip Packard with the support of senior management on an AML reputational and legal perspective to onboard the prospective client, Jeffrey Epstein."
Kirby had pushed: "I realized I never heard back for the below clearance approval. Please let me know as soon as possible as we are now moving ahead with this client and would like to open accounts ASAP."
Andrea Klingenberg cc'd (AML). Andrew Kisz processed the clearance.
WHY THIS MATTERS: This is the ORIGINAL CLEARANCE DOCUMENT — the actual mechanism by which AML compliance was overridden. The AML system worked correctly: it flagged "positive matches... negative information based on reputation." But AML Compliance cleared the alerts solely because of "the attached email approval from Chip Packard with the support of senior management." Kirby pushed urgency from the business line ("open accounts ASAP"). This clearance was then reused across 6+ entity account openings — every Epstein entity at DB was opened on the strength of this single Packard override. This is what the NYDFS consent order describes: senior management overriding AML alerts with a single email that became the permanent justification for the entire relationship.
WHAT THIS SHOWS AND DOES NOT SHOW: This document establishes the exact mechanism by which Packard's Approval Email was operationalized — AML flagged Epstein, Packard overrode, and Kisz processed the clearance. It was then reused for every subsequent account opening. This documents the compliance override but does not establish that Packard acted improperly — he may have conducted a legitimate assessment. The NYDFS found the bank's reliance on this email to be a "major compliance failure."