EFTA01383916, EFTA01384810, EFTA01384859 (Nov 7, 2018): When negative media triggered a compliance review of the Epstein relationship, Oldfield actively argued for continuing:
WHY THIS MATTERS: Oldfield was not a passive custodian of an inherited relationship — he was an active advocate for keeping Epstein as a client. His characterizations came directly from Epstein's own lawyers' talking points, which he relayed to compliance as if they were independent assessments. Six days later, Gallivan approved continuing the relationship (EFTA01383915). Oldfield's lobbying provided the business-line justification that Gallivan and Hart relied upon.
WHAT THIS SHOWS AND DOES NOT SHOW: Oldfield actively championed the Epstein relationship within DB's internal review process, using language that minimized the allegations and suggested the concerns were overblown. This documents advocacy, not knowledge of criminal conduct — Oldfield may have genuinely believed the characterizations he relayed. The consent order states RM-2 was "not made aware by anyone at the Bank of the three conditions the ARRC placed on the relationship."