- Title: Managing Director, Head of Compliance, Americas
- Evidence: Authored the February 6, 2015 ARRC conditions email — the three conditions the ARRC placed on the Epstein relationship. Wrote: "As you know, we agreed last week at RRC to continue business as usual with Jeff Epstein based upon Chip Packard's due diligence visit with him." (EFTA01479329)
- Significance: Ford's email is the document that AML OFFICER-2 later "misinterpreted." The conditions she wrote were clear; the misinterpretation was downstream.
- Note: The consent order mentions the "Head of AML Compliance" referenced in the 2013 Approval Email was "no longer at the Bank" by 2015. Ford held the 2015 compliance head role — the 2013 AML head was a different person.
- Role: ARRC member
- Evidence: Involved in reputational risk decisions on Epstein. Sabba was directed to contact her about Gratitude America account opening (EFTA01479329). Named in ARRC email chains.
- Docs: EFTA01479319, EFTA01479329
- Role: Compliance, Deutsche Bank Americas
- Evidence: Forwarded Jan Ford's ARRC conditions to Sabba. Deferred Gratitude America question to Saracco. Marked ARRC email as confidential: "must not be shared with any third party (including the client)."
- Docs: EFTA01479242, EFTA01479315, EFTA01479329
- Role: ARRC / compliance
- Evidence: CC'd on Jan Ford's Feb 6, 2015 ARRC email alongside Carol Saracco.
- Docs: EFTA01479329
- Role: DB team, account operations
- Evidence: CC'd on Epstein account opening emails Jan 2016 alongside Morris, Stevens, Stepanian, Sabba (EFTA01385067).
- Docs: EFTA01385067
- Title: Analyst, KCP Americas
- Evidence: Enhanced due diligence on Epstein-related matters (EFTA01387326). Handled $1.68M Southern Financial margin call (Aug 25, 2015) — emailed Richard Kahn (cc Morris, Oldfield, Indyke, Sabba, Stepanian) about EURUSD Risk Reversals triggering $1,680,000 margin call from Friday-to-Monday FX move (EFTA01357884).
- Docs: EFTA01387326, EFTA01357884
- Title: Director, AML Business Risk, Deutsche Bank Wealth Management, 60 Wall St
- Evidence: Escalated overdraft issue on Epstein personal account #35266976 to Morris and Litchford (EFTA01477718). Part of the fraud/closure chain — account had been in overdraft for 6+ days due to external fraudulent preauthorized debits. 🔥🔥🔥 Explicitly flagged Epstein as high risk Sep 4, 2013 (EFTA01360710): "this is a high risk relationship due to the negative media and criminal convictions for Mr. Epstein." Brash to Lightbody AND Franklin (primary recipients), Michael Vila, cc Amanda Kirby. From the very first KYC queue assignment, DB's AML team explicitly identified Epstein as a convicted criminal posing high risk. This email CONFIRMS both AML Officer candidates (Franklin/Lightbody) received Day 1 high-risk notification. Everything that followed was done with full knowledge.
- Docs: EFTA01477718, EFTA01477721, EFTA01360710
- Role: AML Compliance
- Evidence: CLEARED RDC/PCR alerts for both Jeffrey Epstein and Darren Indyke in June 2017 (EFTA01297231): "CLEARED: RDC/PCR Alerts for Jeffrey Epstein and Darren Indyke." Sent to Cynthia Rodriguez, cc PWMUS AMLKYC. This clearance came just weeks before the Indyke structuring confrontation (July 2017).
- Docs: EFTA01297231
- Role: Compliance / operational oversight → Primary derivatives sales contact (by Feb 2015) → Post-Morris era servicing
- Evidence: Challenged Morris on Epstein litigation history (EFTA01386025). Escalated Gratitude America account opening through compliance chain. Primary compliance liaison to business on Epstein matters. Epstein demanded his replacement (EFTA01458792, Nov 8, 2015): "can i be covered by someone else besides daniel" — Epstein objected to Sabba's trading advice on EUR 1.12 calls. Became primary sales contact on Southern Financial derivatives valuations replacing Tazia Smith by Feb 2015 (EFTA01472342). Structured "Twitter-style trade" screen for S&P 500 replication (EFTA01472293). Coordinated SFL/Gratitude America derivative report March 2016 (EFTA01477548). Post-Morris era (Jan 2017) — continued servicing Epstein alongside Oldfield, referencing April 2015 conversations that included Morris: "we discussed AB financing with JE in April 2015" (EFTA01385217).
- Docs: EFTA01386025, EFTA01479304, EFTA01479311, EFTA01470457, EFTA01458792, EFTA01472342, EFTA01472293, EFTA01477548, EFTA01385217
- Role: Operational risk/controls
- Evidence: No authority over daily banking limits — when McGrath escalated Epstein's $40K cash withdrawal request to exceed daily limits, Yablochnik responded: "I have no authority to overwrite daily limits on banking accounts. I would talk to Charlie." Sent from BlackBerry. Part of operational controls team handling withdrawal limit escalations (EFTA01345543/547/554/559).
- Docs: EFTA01345543, EFTA01345547, EFTA01345554, EFTA01345559
- Title: DB Services New Jersey
- Evidence: Account status management, Jersey City operations. Listed among DB personnel in operational context (referenced in batch findings).
- Docs: Referenced in Batch 20-23 findings