[GRADE A1 — Internal DB compliance email]
EFTA01479252 (Dec 9, 2015): AML Compliance questioned Morris about an outgoing wire sent 8/14/15 to FT REAL ESTATE (FIRSTBANK PUERTO RICO) in the amount of $400,000.00. Questions demanded: purpose of wire, relationship to FT Real Estate, domicile of FT Real Estate. Response required within 7 business days.
Financial Structure: $400K wire from Epstein's DB account to a real estate entity at FirstBank Puerto Rico. FT Real Estate = potential Epstein property entity in Puerto Rico, noteworthy given Epstein's USVI operations and real estate holdings across the Caribbean.
[GRADE A1 — Internal DB compliance emails/meeting notes]
EFTA01346001 (Jun 23, 2017): Cherie Quigley to Ying Wang/Rob Wang:
"Did we file a SAIF on him recently? I think we need to file another and raise this issue, 3 consecutive days of cash withdrawals totaling over $22K and no CTR"
EFTA01346010 (Jul 19, 2017): DB AML identified structuring across two accounts: Darren K. Indyke PLLC (#42953707) and Jeffrey Epstein (#35269691). Indyke withdrawing from both as POA on consecutive days.
Financial Structure: Textbook structuring — consecutive-day cash withdrawals from two separate accounts (personal PLLC + client account as POA), totaling $22K+, deliberately avoiding the $10,000 CTR reporting threshold. No Currency Transaction Report filed. Quigley explicitly identified the gap: no cash alerts triggering, suggested the dollar value threshold might be set too low for this client. This is a potential BSA (Bank Secrecy Act) violation — failure to file CTRs on structured cash activity.