EFTA01297602, EFTA01297650, EFTA01297668, EFTA01297983 (Feb-Aug 2018):
Multiple RDC (Risk Data Check) alerts with Risk Priority: CRITICAL on Jeffrey Edward Epstein (Note: EFTA01297602 is a corporate certificate document, not itself an RDC alert; the RDC alerts are referenced within the KYC case files):
All show aliases "JEFFREY EDWARD EPSTEIN" and "Jeffery Epstein." "Critical" is the highest risk priority in the RDC system.
WHAT THIS SHOWS AND DOES NOT SHOW: Epstein was hitting CRITICAL risk alerts throughout 2018 — the system was flashing red. Multiple KYC cases were triggered in 2018 alone. These are the alerts that Franklin and/or Lightbody would have reviewed as AML Compliance Officer and AML Business Risk, respectively. DB continued the relationship despite these CRITICAL alerts until the December 2018 exit — triggered by the Miami Herald article, not by compliance action on these alerts. This documents the alert generation but does not establish that any specific AML officer failed to act — the institutional decision to continue was made at the business level (Gallivan "comfort," Hart "risk accepted").