EFTA01399488.txt Text dataset_10 View on DOJ

This email chain discusses whether a new account (Butterfly brokerage), linked to Jeffrey Epstein as the grantor of a trust for his employees, should be covered by Deutsche Bank's KCP team, even though the account doesn't meet the standard eligibility requirements. The discussion highlights concerns about compliance, risk management, and potential preferential treatment, given Epstein's involvement and the precedent of 'ring-fenced' accounts for other clients.

Subject

RE: Butterfly brokerage [C] [I]

Sender

Zbynek Kozelsky <ffi

Recipients

Kimberly Hart, Coley Jellin haus

Document ID

—

Date

2018-10-11

Severity

suspicious

Description

The discussion revolves around whether to make an exception for an account linked to Epstein, which raises concerns about potential compliance violations or preferential treatment. While not direct evidence of illegal activity, it warrants further investigation.

Content Type

first_hand

Likelihood

possible

Description

The discussion of 'ring-fencing' and 'special controls' for certain clients raises the possibility of preferential treatment or bending the rules, which could potentially be used as leverage.

KCP should only be servicing KCP eligible clients - with the exception of a few clients belonging to Josh Shoshan which have been ring-fenced with special controls (including a quarterly attestation).

This a trust with several of Epstein's employees as beneficiaries, and him as grantor. He will have trading authority along with the trustee, but the assets are no longer his since the trust is irrevocable. So Zia felt we could not combine with his other assets to get to the KCP standard.

• The discussion about making an exception for the Butterfly brokerage account to be covered by KCP despite not meeting the standard requirements.
• The mention of 'ring-fenced' accounts with 'special controls' for Josh Shoshan, suggesting potential preferential treatment or deviation from standard procedures.
• The involvement of Epstein as the grantor of the trust, given his history.

Context

The involvement of Jeffrey Epstein and the discussion of potential exceptions to standard banking procedures could be of interest to the media.

Media Worthy

Yes

• KCP coverage of clients which didn't meet KCP standards
• Risk of having an account covered by KCP team without KCP qualifying paperwork, 2110/50 million and big-brother letter etc.

Business dealingsFinancial transactions/money flowCompliance issuesEmployment/staffing

Zbynek KozelskyKimberly HartColey Jellinghauszia MemonDiana CanterFunda BozkurtJosh ShoshanIgorJeff RothStew OldfieldBradley GillinRichard KahnEpstein

Deutsche Bank Securities Inc.Deutsche Bank Wealth ManagementDeutsche Bank Trust Company AmericasInvestment Solutions Group US & Latin AmericaHBRK Associates Inc.

New York, NYLondon

Deutsche Bank

Tone

Professional

Purpose

To discuss whether a new account (Butterfly brokerage) should be covered by the KCP team at Deutsche Bank, given that the POA is a KCP client but the account itself doesn't meet KCP eligibility standards.

Significance

The email chain reveals internal discussions about compliance and risk management related to client eligibility for specific services (KCP) at Deutsche Bank. The involvement of Epstein as the grantor of a trust adds a layer of complexity and potential scrutiny.

File Name

EFTA01399488.txt

Dataset

dataset_10

Type

Text

Model

gemini-2.0-flash-001

Processed

2026-02-07T18:43:15.286863

DOJ Source

View on DOJ