Illegal Activity
suspicious
Blackmail
none
Date
2016-12-20
Document Type
email_chain
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:42
Summary
This email chain documents Deutsche Bank's AML compliance team's efforts to trace the source of funds for a wire transfer into THE HAZE TRUST account, which is associated with Jeffrey Epstein. The team faces challenges in identifying the origin of the funds and seeks clarification on the purpose and beneficiaries of the transactions, raising potential concerns about money laundering.
Metadata
- Subject
- RE: URGENT - THIRD REQUEST''''' RE: Inquiry Regarding THE HAZE TRUST, Account# Alert# SAM1788880 [I]
- Sender
- Vahe Stepanian
- Recipients
- Stewart Oldfield, Zbynek Kozelsky, Cynthia Rodriguez, PWM AMLCompliance, Joshua Shoshan, Donald Summer, Cherie Quigley, Amlcompliance Inquiries
- Document ID
- SAM1788880 [I]
- Date
- 2016-12-20
Illegal Activity
- Severity
- suspicious
- Description
- The document details the AML compliance team's struggle to identify the source of funds related to Jeffrey Epstein's account, which raises concerns about potential money laundering.
- Categories
- Money Laundering Indicators
- Content Type
- first_hand
Evidence:
- The complexity of the transactions and the difficulty in tracing the source of funds raise suspicions of potential money laundering.
Relationships 5
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Vahe Stepanian | Colleagues | Stewart Oldfield | Discussing meeting up for a drink and how to handle the AML inquiry. |
| Danya Friedman | Compliance Officer | PWM AML Compliance | Requesting information about the source of funds for audit purposes. |
| Cynthia Rodriguez | Client Relationship | Jeffrey Epstein | Cynthia identifies Jeffrey Epstein as the beneficiary and originating party for an art purchase. |
| Zbynek Kozelsky | Colleague | Amlcompliance Inquiries | Zbynek asks AML compliance what else they need to close the loop on the HSBC wire. |
| Stewart Oldfield | Colleagues | Vahe Stepanian | Stewart is the primary relationship manager for the client and can confirm details. |
Notable Quotes 2
Client is a billionaire. It's not like this is a specific $6mm of his. Most of his wealth comes from investments and advisory fees.
Please specify the originating account so that I can confirm this transaction, after searching PRIME and DB FORCE (our PB systems, I am unable to locate the transaction). Also, any idea as to why, if this is an internal transfer, that funds are being sent through HSBC?
Red Flags 3
- Difficulty in tracing the source of funds.
- Use of multiple accounts and entities for transactions.
- Funds being sent through HSBC even for internal transfers.
Financial Information
Amounts:6,186,980.68 USD23,000,000.00 USD25,000,000.00 USD5,000,000.00 USD
Assets:
- Art
Transactions:
- Incoming wire of $6,186,980.68 from HSBC SECURITIES SERVICES (IRELAND) DAC at HSBC BANK USA, NATIONAL ASSOCIATION
- Outgoing transfer of $25,000,000.00 to AP NARROWS HOLDING LP/BMO TRUSTEE at CDEC CLEARING ACCOUNT through BANK OF AMERICA, N.A., NY
- Outgoing transfer of $5,000,000.00 to LDB 2011 LLC/BMO TRUSTEE at CDEC CLEARING ACCOUNT through BANK OF AMERICA, N.A., NY
Public Knowledge
- Context
- The involvement of Jeffrey Epstein and the AML compliance issues at Deutsche Bank would likely be of interest to the media.
- Media Worthy
- Yes
Legal Compliance
- Potential AML compliance issues due to difficulty in tracing the source of funds.
- Multiple requests for information indicate a lack of initial clarity and potential red flags.
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowLegal matters/litigationBusiness dealingsCommunications/correspondenceAllegations/complaintsArt PurchaseAnti-Money Laundering (AML) Compliance
People 13
Organizations 15
THE HAZE TRUSTDeutsche BankPWM AML ComplianceHSBC SECURITIES SERVICES (IRELAND) DACHSBC BANK USA, NATIONAL ASSOCIATIONDeutsche Bank Securities Inc.Deutsche Asset & Wealth ManagementDeutsche Bank Trust Company AmericasSouthern Trust Company, IncBank of New YorkAP NARROWS HOLDING LPBMO TRUSTEECDEC CLEARING ACCOUNTBANK OF AMERICA, N.A., NYLDB 2011 LLC
Locations 6
New YorkNew York, NY 1000560 Wall St., 23 Floor345 Park Avenue, 26th Floor345 Park Avenue, 10154-0004 New York, NY, USAIreland
Financial Entities 4
HSBCBank of AmericaBank of New YorkBMO Trustee
Text Analysis
- Tone
- Professional
- Purpose
- The purpose of this email chain is to determine the source of funds for a wire transfer into THE HAZE TRUST account and to comply with AML regulations.
- Significance
- This document is significant because it shows the AML compliance process at Deutsche Bank and the efforts to trace the origin of funds related to Jeffrey Epstein's account.
File Info
- File Name
- EFTA01426353.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:42:12.581019
- DOJ Source
- View on DOJ