EFTA01345664 (Jul 19, 2017): Ying-A Wang to Oldfield, Salit, Liconte: "DB AML has identified a history of cash structuring activity in accounts for Darren K. Indyke PLLC and for Jeffrey Epstein."
Oldfield's response: "Happy to chat whenever you like. I'm here now."
WHAT THIS SHOWS AND DOES NOT SHOW: AML formally notified the Relationship Manager of documented cash structuring. Oldfield was cooperative but took no termination action. The casual tone — "Happy to chat" — contrasts with the severity of the AML finding. This is the same structuring notification referenced in the consent order. Oldfield remained the RM through December 2018 termination.
EFTA01346044, EFTA01346045, EFTA01346046 (Mar 20-21, 2018): AML discovered the debit card limit had been increased from $1K to $12K in December 2017 without AML approval:
EFTA01346033, EFTA01346035, EFTA01346039 (Mar 19, 2018): Anthony Western (Product line) retroactively approved: "Approved. Please note you need business line approval as well and you need to notify AML of the increase." Hildegarde Berrios (VP Banking Specialist) had initiated the retroactive paperwork.
WHAT THIS SHOWS AND DOES NOT SHOW: The business line bypassed AML controls to increase cash access for a client with a documented structuring history. AML only discovered the unauthorized increase 3 months later during a routine Q4 review. AML retroactively approved — after the fact. This occurred AFTER the July 2017 structuring confrontation — the opposite of tightening controls. Under Oldfield's management.
EFTA01345811, EFTA01346074, EFTA01346079, EFTA01346082, EFTA01346149 (Jan-Feb 2018):
Rodriguez to Bella Klein (Jan 8, 2018): "Our management team has confirmed that Mr. Epstein's debit card is fully active and has a debit limit of $12k. The only other issue they foresee happening is that the ATM machine itself has a foreign debit card limit of $1,000."
Rodriguez (Feb 6, 2018): "Deutsche Bank is currently in negotiations with U.S. retail banks within the vicinity in attempts to provide our clients with their personal maximum ATM withdrawal amounts."
WHAT THIS SHOWS AND DOES NOT SHOW: DB was actively negotiating with USVI retail banks to increase ATM withdrawal limits for Epstein's debit card — essentially working to maximize cash access for a client with a known structuring history in the U.S. Virgin Islands. Rodriguez (Oldfield's assistant) was coordinating directly with Bella Klein (Epstein staff). The "foreign debit card limit" problem arose because Epstein was trying to access cash at ATMs in the USVI.