Chapter 1: Compliance v. complicity: The ‘underbelly’ of bank culture

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January 22, 2015.

It was a bitterly cold day, the temperature near freezing, when two senior leaders from Deutsche Bank came knocking on the 15-foot oak entry doors of Jeffrey Epstein’s New York town house.

The financial advisers were there on pressing business. Certain issues involving the customer’s accounts had been escalated by the bank’s anti-financial crime department, and the gentlemen were there to give the convicted pedophile a chance to address them—discreetly.

The irony of holding the meeting in Epstein’s multimillion-dollar town house, where countless acts of sexual abuse and commercial sex acts had taken place, strikes with the force of 20-20 hindsight now. It might have been lost on the Deutsche Bank employees on that day. However, they were at least aware of one accuser’s claim of abuse at that location.

In winter 2015, the legal and factual bases for claims against Epstein’s financial institutions (FIs) for know your customer (KYC) and customer due diligence (CDD) failures were far from certain. That reckoning would come years later.

Epstein, who loved his privacy, was back in the headlines. His 2008 conviction of solicitation and procurement of a minor to engage in prostitution was inconveniently resurfacing. The restoked heat was precipitated by a federal appeals court having ruled certain victims would be granted access to the details of his plea bargain, potentially reopening their cases.

At the same time, fresh allegations of sexual abuse and trafficking were trending. A woman named Virginia Giuffre had just revealed publicly that, while a minor, she was trafficked by Epstein and forced to engage in sexual activity with his friends, including a member of British royalty, in London, the U.S. Virgin Islands, and New York.

All the brouhaha in the media was raising eyebrows at Deutsche Bank.

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