Internal communications and documents reviewed by Financial Times reveal how Germany’s largest bank maintained a lucrative relationship with Jeffrey Epstein for years, even as compliance officers raised repeated red flags about suspicious transactions, reputational risks, and the financier’s criminal past. The records offer one of the clearest pictures yet of how commercial ambition, weak oversight, and fragmented accountability allowed a convicted sex offender to move hundreds of millions of dollars through a major global institution.
In May 2018, compliance staff questioned why thousands of dollars had been transferred from an account meant for payroll to a Moscow bank to cover what relationship managers described as school tuition for a “friend.” When anti-money-laundering officials pressed further, they were told Epstein’s staff had the flexibility to use any account for one-off transfers. Such exchanges, repeated across years of correspondence, illustrate what investigators later characterized as a pattern of accommodation rather than scrutiny.
Epstein had turned to the German lender in 2013 after being cut off by JPMorgan Chase, shifting vast sums of wealth and gaining access to elite private-banking services. According to information later provided to prosecutors, the bank allowed him to send money abroad to cover expenses for young women, transferring roughly $875,000 to individuals described internally as “ostensible foreign models” during the six years it handled his finances. The institution has since paid more than $225 million in fines and settlements tied to Epstein-related failures and separate compliance lapses linked to a Russian money-laundering scheme, acknowledging what it called the “error” of onboarding him and weaknesses in its controls.
The relationship began amid an aggressive expansion of the bank’s wealth management division under then co-chief executive Anshu Jain, who sought to attract ultra-wealthy clients from rival firms. A key hire was private banker Paul Morris, whose client list included Epstein. Within months of joining, Morris was arranging meetings to bring Epstein’s business over. Despite Epstein’s criminal conviction, senior staff decided that reputational risk committee review was unnecessary if standard due diligence checks revealed nothing further. By October 2013, about $180 million had landed in new accounts, prompting congratulatory internal emails celebrating the win.
Executives soon viewed Epstein not only as a client but as a gateway to other powerful figures. Bankers highlighted his connections to financiers such as Leon Black, co-founder of Apollo Global Management, and discussed opportunities to deepen relationships across his network. Internal notes described Epstein as a potential “Tier 1 relationship” capable of generating substantial new business, even as some employees expressed discomfort about servicing such a controversial figure.
Compliance concerns surfaced early. Alerts flagged complex webs of trusts and associates, including references to Ghislaine Maxwell, later convicted for her role in Epstein’s crimes. Other warnings pointed to unusual cash withdrawals and structured transactions designed to avoid reporting thresholds. In one instance, the bank approved raising Epstein’s debit card withdrawal limit to $12,000 despite repeated suspicious activity reports. Regulators would later conclude that the bank’s failure to recognize the risks constituted a major compliance breakdown.
The documents also show how language and routine normalized activity that might otherwise have triggered deeper investigations. Payments to women in eastern Europe and Russia were at one point deemed “normal for this client,” while internal teams accepted explanations that entities receiving funds were educational institutions or modeling agencies. The bank processed transfers through offshore companies and sent $80,000 to an agency linked to Jean-Luc Brunel, later accused of trafficking-related offenses before his death in custody.
Epstein’s appetite for complex trades and currency bets generated revenue, making him attractive to business units even as risk teams struggled to monitor his activity. He was enrolled in an exclusive client program designed for individuals worth more than $100 million, with bankers describing him as both highly sophisticated and exceptionally demanding. Traders often chased him for confirmations on multimillion-dollar deals, while internal correspondence recorded frustrations with what staff called his challenging behavior.
By 2017, compliance officers again warned about the future of the relationship after identifying repeated suspicious transactions. Yet the accounts remained active, and some services were even expanded. Relationship managers defended the client internally, arguing that Epstein had been approved repeatedly by senior management and generated significant annual revenue.
As media scrutiny intensified, including reporting by Miami Herald that revisited allegations against Epstein, risk officials began pressing more forcefully for answers. Questions arose about payments linked to trusts and individuals connected to Epstein’s personal life, as well as his associations with prominent figures such as Bill Clinton and Prince Andrew, which had already classified him internally as a politically exposed client.
Only in December 2018 did the bank decide to terminate the relationship, informing Epstein that he would need to move his assets elsewhere. Even then, the separation dragged on, with deadline extensions granted and transactions continuing as accounts were slowly wound down. Emails show bankers urging colleagues to keep facilitating wire transfers while awaiting closure.
When Epstein was arrested in July 2019 on federal sex-trafficking charges, many of his accounts were technically still open, though nearly empty. Internal messages marked “URGENT” called for their immediate closure. One account balance stood at just $33.77, prompting a banker to remark that the remaining funds would have to be returned by cheque.
The fallout has included regulatory penalties, internal disciplinary actions, and sustained scrutiny of how global banks handle high-risk clients. One relationship manager was later dismissed for what filings described as a lack of expected diligence. The institution has said it has since overhauled compliance systems and strengthened controls to prevent similar failures.
