[GRADE A1 — NYDFS Consent Order]
| Field | Value |
|---|---|
| Opened | January 24, 2014 (consent order date; KYC EFTA01295581 shows checking/MM opened 10/9/2013 — may reflect different account openings or trust registration vs. account activation) |
| Account types | Checking + money market |
| Stated purpose | "to pay all expenses/disbursements related to the trust such as taxes, trust fee, etc." |
| Beneficiaries | CC-1, CC-2, CC-3 + "women with Eastern European surnames" |
| Total wires | $2,650,000 (120+ transfers) |
| Stated wire purposes | "hotel expenses, tuition, and rent" |
| Cleared by | RC-1 (Tazia Smith) citing Approval Email from EXECUTIVE-1 |
The consent order states the trust's beneficiary structure "created the very real risk that payments through the Trust could be used to further or coverup criminal activity and perhaps even to endanger more young women."
WHAT THIS SHOWS AND DOES NOT SHOW: The consent order establishes that known co-conspirators were named beneficiaries of a trust instrument through which $2.65 million flowed while the bank was aware of the co-conspirator designations. This documents financial dependency between co-conspirators and Epstein's wealth infrastructure. It does not establish that specific wire transfers funded criminal activity — the consent order characterizes the arrangement as creating "the very real risk," not as confirming that the risk materialized.