INVESTIGATION LINE 3: THE HAZE TRUST AML INQUIRY
Forensic Financial Analysis of Deutsche Bank's Anti-Money Laundering Process for Jeffrey Epstein's Largest Trust Vehicle
Investigator: Forensic Financial Analysis Unit
Database: the primary document text database -- DOJ Epstein Files (1,808,915 redacted fragments; 107,422 extracted entities; 39,588 reconstructed pages)
Date of Analysis: 2026-02-05
Classification: INVESTIGATIVE REPORT
EXECUTIVE SUMMARY
The Haze Trust was Jeffrey Epstein's single largest financial vehicle held at Deutsche Bank, with balances ranging from $2.5 million to $49.5 million across the period documented in these files (2011-2019). Deutsche Bank's AML Compliance unit triggered an internal inquiry on the Haze Trust under Alert# SAM 1788880, tied to Account# N4G024943. The inquiry was escalated to an "URGENT - THIRD REQUEST" level -- meaning compliance officers had to ask the private wealth management team at least three times for basic information about the account. Despite the Haze Trust holding tens of millions of dollars, despite the AML alert, and despite the fact that DB ultimately filed Suspicious Activity Reports on Epstein after his July 2019 arrest, the evidence in these files strongly suggests that DB's AML process was performative rather than genuine -- a compliance theater designed to generate paper trails rather than prevent illicit financial activity.
Total EFTA documents referencing The Haze Trust: 300 unique documents
Haze Trust bank statements recovered (EFTA01501000-EFTA01504000 range): 207 unique documents
Alert# SAM 1788880 referenced across: 11 distinct EFTA documents
I. THE HAZE TRUST: IDENTIFICATION AND STRUCTURE
Account Fundamentals
| Field | Value | Source |
|---|---|---|
| Account Name | THE HAZE TRUST | Multiple redactions across 300 documents |
| Account Number | N4G024943 | EFTA01369019 (conf. 0.99) |
| AML Alert Number | SAM 1788880 | EFTA01369019, EFTA01413743, EFTA01414241 |
| Account Category | D (Deposit) and M (Managed) -- held in both categories | EFTA01381149, EFTA01381246 |
| Authorized Signer | Richard Kahn (Trustee) | EFTA01360448, EFTA01282292 |
| Primary Custodian Bank | Deutsche Bank Trust Company Americas | Multiple documents |
Key Identifying Quote
From EFTA01369019 (confidence 0.99):
"Vahe Stepanian; Donald Summer; Regarding THE HAZE TRUST, Account# N4G024943, Alert# SAM 1788880 [I]"
This single redacted fragment contains the full investigative thread identifier: the compliance officer (Stepanian), the relationship manager (Summer), the trust name, account number, and AML alert number.
II. FINANCIAL TOPOLOGY: THE HAZE TRUST WITHIN EPSTEIN'S SHELL NETWORK
The EFTA01381149 Consolidation Report (08/17/2018)
The most critical document for understanding Epstein's financial architecture at Deutsche Bank is EFTA01381149, a "LARGE, ZERO AND NEGATIVE BALANCES" report (RM CODE 82289) dated 08/17/18. This document, recovered with 0.99 confidence, reveals the complete list of Epstein-related entities at DB:
Tier 1 -- Personal Accounts:
| Entity | Category | Balance |
|--------|----------|---------|
| JEFFREY EPSTEIN | N | $1,243,515.74 |
Tier 2 -- Operating Shells (Category D):
| Entity | Category | Balance |
|--------|----------|---------|
| SOUTHERN FINANCIAL LLC | D | $376,315.00 |
| PLAN D, LLC | D | $326,685.34 |
| JEGE, LLC | D | $285,583.43 |
| DARREN K. INDYKE PLLC | D | $259,740.02 |
| HBRK ASSOCIATES, INC | D | $149,498.33 |
| NES LLC | D | $264,466.13 |
Tier 3 -- Charitable/Investment Vehicles:
| Entity | Category | Balance |
|--------|----------|---------|
| GRATITUDE AMERICA, LTD | N | $2,075,025.07 |
| ZORRO MANAGEMENT, LLC | O | $424,475.56 |
Tier 4 -- THE HAZE TRUST (Two Accounts):
| Entity | Category | Balance |
|--------|----------|---------|
| THE HAZE TRUST | D | $2,503,667.84 |
| THE HAZE TRUST | D | $40,583,100.79 |
Tier 5 -- Managed Trust Accounts:
| Entity | Category | Balance |
|--------|----------|---------|
| SOUTHERN TRUST COMPANY, INC. | M | $704,736.63 |
| BUTTERFLY TRUST | M | $323,679.36 (est.) |
| GRATITUDE AMERICA, LTD | M | $268,350.45 |
Tier 6 -- Additional Entities:
| Entity | Category | Balance |
|--------|----------|---------|
| SOUTHERN FINANCIAL LLC | D | $534,440.04 |
| SOUTHERN TRUST COMPANY, INC. | D | $102,917.53 |
Critical Finding: The Haze Trust Dominated the Portfolio
Combining both Haze Trust accounts on 08/17/2018:
- Haze Trust Total: $43,086,768.63
- Total Epstein-related balances (Haze Trust peak): ~$49,500,000 (Note: DS9 reveals the total Epstein relationship at DB was approximately $230-330 million per EFTA00128826 and EFTA00165748; the $49M represents only the Haze Trust peak, not the total relationship.)
- Haze Trust as percentage of total: ~88%
The Haze Trust was not merely one account among many. It was the overwhelmingly dominant financial vehicle in Epstein's Deutsche Bank relationship.
III. THE HAZE TRUST BALANCE TRAJECTORY
Recovered from the "Large, Zero and Negative Balances" reports (RM CODE 82289):
| Date | EFTA Source | Haze Trust Balance | Notes |
|---|---|---|---|
| ~06/2017 | EFTA01415016 | ~$5,075+ (partial) | Earliest recovered balance |
| ~06/20/2017 | EFTA01414998 | $21,035,275.90 | Balance growth |
| ~05/16/2018 | EFTA01415223 | $49,397,167.47 | Near-peak |
| ~05/18/2018 | EFTA01415225 | $49,397,167.47 | Stable |
| ~05/2018 | EFTA01415061 | $49,279,231.93 | Slight decrease |
| ~06/07/2018 | EFTA01415119 | ~$44-49M (partial) | Range estimate |
| 06/21/2018 | EFTA01381246 | $49,460,098.13 | Peak balance |
| 06/25/2018 | EFTA01415125 | ~$49M (partial) | Near peak |
| 07/20/2018 | EFTA01415196 | $40,521,596.75 | Declining |
| 08/17/2018 | EFTA01381149 | $40,583,100.79 + $2,503,667.84 | Two accounts |
| 08/28/2018 | EFTA01413971 | $35,583,100.79 | Continued decline |
| ~10/18/2018 | EFTA01427866 | Not fully recovered | In balance report |
| ~Late 2018 | EFTA01427976 | $7,717,706.44 | Significant drawdown |
| ~Late 2018 | EFTA01432135 | $7,719,110.44 | Stable low range |
| 01/14/2019 | EFTA01432198 | $8,789,938.49 | Slight recovery |
| ~Undated | EFTA01430852 | $49,233,909.70 | (May be earlier 2018) |
| 04/26/2019 | EFTA01421252 | (Referenced, amount unclear) | Last pre-arrest reference |
Key Observation: The $40M Drawdown
Between June 2018 ($49.5M peak) and late 2018 ($7.7M), approximately $41.7 million was withdrawn from the Haze Trust. This coincides with the period when:
1. The AML inquiry was actively escalating (URGENT - THIRD REQUEST)
2. Deutsche Bank was under regulatory pressure regarding its Epstein relationship
3. Epstein's accounts were being prepared for closure
The question of where $41.7 million went remains one of the most significant unanswered questions in these files.
IV. THE AML INQUIRY: CHRONOLOGICAL RECONSTRUCTION
Phase 1: Early References (Pre-Alert)
EFTA01287132, EFTA01287147 -- Earliest recovered Haze Trust references, marked "CONFIDENTIAL - PUR[POSES]" (EFTA01287132, conf. 0.81).
EFTA01344415 -- Reference to "Jeepers and Haze A[ccoun]t" -- suggests the Haze Trust was discussed alongside another entity ("Jeepers") in an early review context.
EFTA01361724 -- Reference to "Haze, Foundation)" and "[par]ticipant information" -- suggests a KYC review examining the participants/beneficiaries of the Haze Trust and a related foundation.
Phase 2: AML Alert Triggered (2014-2017)
EFTA01360448 (confidence 0.99) -- A pivotal document showing DB's initial AML response:
"has no relation (Richard Kahn is th[e] authorized signer) Please clear t[he alert]"
"alert from an AML p[erspective/process]"
"tac[h]e[d]; t[h]e prospective c[l]ient [h]as no re[l]ati[on]"
This document reveals that when an AML alert was triggered, the response was to clear the alert based on the explanation that Richard Kahn (Epstein's attorney) was the authorized signer and that the prospective client had "no relation" to the flagged concern. This is a textbook example of relationship managers providing explanations to dismiss AML flags rather than investigating them.
EFTA01360449 -- "MMUS AMLKYC: 11/19/2014 09:38 AM" -- Dates the AML/KYC process to at least November 19, 2014.
Phase 3: The SAM 1788880 Alert and Inquiry (2017-2018)
The formal AML inquiry was triggered under Alert# SAM 1788880, marked as classification [I] (Inquiry level).
EFTA01357853 -- The originating inquiry email (confidence 0.99):
"Vahe Ste[p]anian; Amlcompliance Inq[uiries]; Regarding THE HAZE TRUST"
"[Account#] N4G024943, Alert# SAM 1788[880]"
EFTA01365654 -- Follow-up (confidence 0.99):
"[Don]ald Summer[s]; [Inquir]y Regarding THE HAZE TRUST, Account[#]"
"[Joshu]a Shoshan; RE: URGENT - THIR[D REQUEST]"
This confirms the inquiry had already reached the THIRD REQUEST stage, meaning compliance had been stonewalled at least twice.
Phase 4: URGENT -- THIRD REQUEST Escalation
The most damning evidence of DB's dysfunctional AML process is the series of "URGENT - THIRD REQUEST" emails. These documents show AML Compliance repeatedly demanding information from the Private Wealth Management team, which was either not responding or providing insufficient answers.
EFTA01360291 (confidence 0.91):
"[Zbyn]ek Kozelsky; HAZE TRUST A[ccount]; N4[G024943]"
"[Compl]iance I[nquiries]; Amlcom[pliance]; [THI]RD REQUEST!!!!!"
Note the five exclamation marks after "THIRD REQUEST" -- a rare display of frustration in formal compliance correspondence.
EFTA01360489 (confidence 0.85-0.81):
"Zbynek Kozelsky; Cyn[thia Rodriguez]"
"[Regar]ding THE HAZE TRUST Acco[u]nt"
"RE URGENT THIRD REQ[UEST]"
EFTA01360491 (confidence 0.94):
"Compliance; THE HAZE TRUST, Acco[unt#]"
"[Amlcom]pliance; - THIRD REQU[EST]"
EFTA01369002 -- The "URGENT - THIRD REQUEST" with full distribution (confidence 0.99):
"C[y]nthia Rodri[g]uez; [J]oshua Shoshan; Amlcompliance; URGENT; THIRD REQUEST; RE [Inqu]i[ry] R[egar]di[ng]"
"[Zbyne]k Kozelsk[y]; [Donald] Summer[s]; THE HAZE TRUST A[ccount#] [N4G02494]4"
EFTA01369017 -- Internal escalation (confidence 0.99):
"Stewart Oldfield; [J]oshua Shoshan; Amlc[ompliance]; RE URGENT THIRD REQUEST"
"Stepanian; Shoshan; E: URGENT - THIRD REQUE[ST]"
"PWM AML; HAZE TRUST A[ccount]"
Phase 5: Multi-Party Email Threads (The Full Cast)
The recovered email threads reveal the complete cast of participants in the AML inquiry:
EFTA01369003 (confidence 0.99):
"[T]o: C[y]nthia Rodr[ig]uez; Vahe Stepanian; [C]c: Joshua Shoshan; Amlcompliance Inq[uiries]; [Su]bj[ect:] RE: [Inqu]i[ry] R[egar]di[ng] THE HAZE TRUS[T]"
EFTA01413743 -- A multi-page email thread (pages 0-10, confidence 0.99):
Page 0:
"Cherie Quigley; Amlcompliance Inquiries; Subject: RE: Inquiry Regarding THE HAZE TRUST, Account[#]; SAM1788880 [I]"
Page 1:"Rodriguez; Zbynek Kozels[ky]; Oldfield; Shoshan; Donald Summer; Cherie Quigley; [Complian]ce Inquiries; Inquiry Regarding THE HAZE TRUST"
Page 4:"Cc: Joshua Shoshan; Cynthia Rodriguez; [Su]bj[ec]t[:] RE[:] I[nqu]i[ry] R[egar]di[ng] THE HAZE TR[UST]"
Page 6:"To: Vahe Stepanian; Amlcompliance I[nquiries]"
EFTA01414241 -- Another multi-page thread (pages 0-16, confidence 0.99):
Page 3:
"Stewart Oldfield; Shoshan; Donald Summe[rs]; [Complia]nce Inquiries; E: URGENT - THIRD REQUEST''''' RE: Inquiry Reg[arding]"
Page 6:"Stewart Oldfield; St[v]epanian; Cc: Joshua Shoshan; Donald Summer; Cherie Quigley; Amlcompliance Inquiries; Subject: RE: Inquiry Regarding THE HAZE TRUST, Account#"
Page 7:"Amlcompliance Inquiries; Subject: RE: Inquiry Regarding THE HAZE TRUST, Account# [REDACTED]; SAM1788880 [I]"
Page 8:"[T]o: Amlcompliance Inquiries; Zb[ynek K]ozelsky; Stewart Oldfield; Vahe Stepanian; [C]c: Joshua Shoshan; Donald Summer"
V. THE PARTICIPANTS: WHO KNEW WHAT
Deutsche Bank AML Compliance Team
| Name | Role | Key Evidence |
|---|---|---|
| Vahe Stepanian | PWM team member (Associate, Wealth Investment Coverage / Key Client Partners) | Named in 100+ redactions; appeared on AML correspondence as the banker being questioned by compliance, not the compliance officer initiating inquiries. DS9 confirms his role as operational banking (wire tracking, account management for Richard Kahn) -- not AML compliance (EFTA00693410, EFTA00169398) |
| Amlcompliance Inquiries ([email protected]) | Shared mailbox | Formal sender/recipient of all inquiry emails |
| Cherie Quigley | AML Compliance (escalation) | Added to thread during URGENT-THIRD REQUEST phase |
| Cynthia Rodriguez | Compliance team member | Cc'd on most inquiry emails; also involved in other account inquiries (LSJE LLC) |
Deutsche Bank Private Wealth Management Team
| Name | Role | Key Evidence |
|---|---|---|
| Stewart Oldfield | PWM Relationship Manager | Named across 20+ Haze Trust documents; primary recipient of compliance inquiries |
| Zbynek Kozelsky | PWM (London/international desk) | Connected to Southern Financial LLC (EFTA01369043); named in URGENT escalations |
| Joshua Shoshan | PWM team member | Cc'd on all Haze Trust inquiry threads |
| Donald Summer(s) | PWM team member | Named alongside Stepanian in the original inquiry; recipient of THIRD REQUEST emails |
| Bradley Gillin | PWM management | Named in related account inquiries |
External Principals
| Name | Role | Key Evidence |
|---|---|---|
| Richard Kahn | Trustee/Authorized Signer | EFTA01360448: "Richard Kahn is th[e] authorized signer"; EFTA01282292: "RICHARD KAHN Trustee" |
| Darren K. Indyke | Epstein attorney/PLLC | Named in consolidation reports; PLLC held separate accounts alongside Haze Trust |
VI. SAR FILING ANALYSIS
Were Suspicious Activity Reports Filed?
Finding: SARs were filed on Epstein, but only AFTER his July 2019 arrest -- not as a result of the Haze Trust AML inquiry.
The SAR-related documents cluster exclusively in August-September 2019, weeks after Epstein's arrest on July 6, 2019:
EFTA01649596 (confidence 0.99):
"[Sub]ect: Fwd: Epstein Significant Activity Report (SAR) - Victim info."
"Thursday, August 15, 2019"
"Aug 15, 2019 11:19 AM"
"Crimes Against Child[ren]"
EFTA01654078 (confidence 0.99):
"Subject: Re: Epstein SAR"
"Subject: RE: Epstein SAR"
"Friday, August 9, 2019 6:13:34 PM"
EFTA01654080 (confidence 0.99):
"[Su]bject: Re: Epstein SAR"
"Frida[y] Au[g]ust 09 2019 6:44 PM"
EFTA01660736 (confidence 0.92):
"[Sub]ject: Re: Epstein SAR"
"[A]ugust 9 2019 at 19:35:53"
"NYPD/FBI"
EFTA01654929 -- Maxwell SARs (confidence 0.99):
"Su[b]ject: Maxwe[ll] SARS"
"Thursday, June 18, 2020 11:52 AM"
EFTA01648786 (confidence 0.88-0.99):
"[Su]bject: Financials and SARs"
"It[']s a total of $30.7 million for Epstein that was worth"
Critical Finding: No SAR Was Filed During the Haze Trust AML Inquiry
Despite:
- Alert# SAM 1788880 being triggered
- The inquiry escalating to "URGENT - THIRD REQUEST!!!!!" level
- Account balances reaching $49.5 million
- $41.7 million being withdrawn in a compressed timeframe
- The compliance team being repeatedly stonewalled by PWM
There is no evidence in these files of a SAR being filed on the Haze Trust or any Epstein entity prior to his arrest. The SARs that were eventually filed (August 2019) were reactive, not proactive -- triggered by law enforcement action, not by DB's own compliance process.
VII. FinCEN CONNECTIONS
FinCEN References in the Database
EFTA00020176, EFTA00032293 -- DOJ/law enforcement documents:
"[Sub]ject: RE: Epstein (FinCEN records)"
These indicate that law enforcement obtained FinCEN records on Epstein -- meaning financial intelligence was available about Epstein's transactions through the FinCEN system. The question is whether DB was contributing to that intelligence or only discovered it after the fact.
EFTA01369188 -- DB internal document:
"Subject: FinCEN CDD Rule; Custo[mer Due Diligence]"
EFTA01372668, EFTA01372670 -- FinCEN CDD Rule implementation (confidence 0.99):
"Dawn Forbes; [Pra]shant Mahendru; Barry H Morr[is]; [I]nsun Chung; Mary C Keaveney; [Su]bject: RE: Important Update: FinCen CD[D Rule]"
"Subject: RE: Important Update New Regulation: FinCen CDD Rule"
These documents show DB was actively implementing FinCEN's Customer Due Diligence (CDD) rule during the same period as the Haze Trust AML inquiry. The CDD rule required enhanced due diligence on beneficial owners of legal entity customers -- precisely the type of scrutiny that should have been applied to the Haze Trust.
VIII. THE AML ALERT DISMISSAL PATTERN
EFTA01360448: The "Please Clear" Document
This document is perhaps the most revealing single piece of evidence about how DB's AML process functioned in practice:
Fragment 1 (conf. 0.99):
"has no relation (Richard Kahn is th[e] authorized signer) Please clear t[he alert]"
Fragment 2 (conf. 0.94):"tac[h]e[d]; t[h]e prospective c[l]ient [h]as no re[l]ati[on]"
Fragment 3 (conf. 0.93):"[ema]il exchange our client [ac]count and sole [a]u[thorized signer]"
Fragment 4 (conf. 0.81):"alert from an AML p[erspective/rocess]"
Interpretation: When an AML alert fired on an Epstein-related account, the PWM team's response was not to investigate the underlying activity but to provide a rationalization ("Richard Kahn is the authorized signer, the prospective client has no relation") and request that compliance "clear the alert." This is the AML equivalent of a police officer being told "nothing to see here" and moving along.
IX. THE HAZE TRUST ACCOUNT STATEMENTS (2011-2013)
EFTA01501365 through EFTA01503234: Bank Statements
The database contains 207 unique EFTA documents in the 01501000-01504000 range referencing the Haze Trust. These are monthly account statements spanning from at least February 2011 through September 2013, with the following date ranges recovered:
| Period | EFTA Source | Key Text |
|---|---|---|
| 2/1/11 - 2/28/11 | EFTA01501365 | "THE HAZE TRUST; Primary Accoun[t]; [For] th[e] P[er]i[o]d 2/1/11 [to] 2/28/11" |
| 7/1/11 - 7/29/11 | EFTA01501460 | "THE HAZE TRUST; Primary Account; [For] th[e] P[er]i[o]d 7/1/11 t[o] 7/29/11" |
| 7/30/11 - 8/31/11 | EFTA01502906 | "THE HAZE TRUST; Primary Account; [For] th[e] P[er]i[o]d 7/30[/1]11 t[o] 8/31/11" |
| 11/1/11 - 11/30/11 | EFTA01501532 | "Primary Account; [For] [t]h[e] P[er]i[o]d 11/1/11 [to] 11/30/11; THE HAZE TRUST" |
| 2/1/12 - 2/29/12 | EFTA01503001 | "Primary Account; THE HAZE TRUST; [For] [t]h[e] P[er]i[o]d 2[/]1/12 [to] 2/29/12" |
| 8/31/13 - 9/30/13 | EFTA01503202 | "THE HAZE TRUST; Primary Account; [For] th[e] P[er]i[o]d 8/31/13 t[o] 9/30/13" |
The DB bank statements begin in 2011, but DS9 reveals the Haze Trust was formed on February 9, 1999 (EFTA00721073, EFTA01193890, EFTA00165655) -- not 1991 as partially read from one OCR artifact. The trust was established under New York law with EIN 13-7185414, Epstein as both Grantor and Trustee, and Darren Indyke designated as successor trustee. The earliest investments (King Street Capital, $10M) date to November 1, 1999. This means the trust was operational for at least 20 years (1999-2019), providing ample time for any genuine AML process to detect suspicious patterns.
X. CONNECTED ENTITIES AND FUND FLOWS
Shell Company Ecosystem (from EFTA01381149 and related balance reports)
The Haze Trust operated alongside at least 15 other Epstein-controlled entities at Deutsche Bank:
Direct Epstein Entities:
1. Jeffrey Epstein (personal account)
2. Southern Financial LLC
3. Southern Trust Company, Inc.
4. Plan D, LLC
5. JEGE, LLC
6. Darren K. Indyke PLLC (and a separate "-" account)
7. HBRK Associates, Inc
8. NES LLC
9. Gratitude America, Ltd
10. Zorro Management, LLC
11. Butterfly Trust
12. Hyperion Air, LLC
13. Neptune, LLC
14. LSJE, LLC
15. Prytanee, LLC
Parallel AML Inquiries on Other Epstein Entities
The same compliance team (Stepanian, Rodriguez, Shoshan) conducted parallel inquiries on other Epstein entities:
EFTA01423777 (confidence 0.99):
"To: Cynthia Rodriguez; Stewart Ol[dfield]; Cc: Amlcompliance Inquiries; Subject: Inquiry Regarding Account [#]82402; DUE J[uly] [1]4 [I]; Client: LSJE, L[LC]"
EFTA01425911 (confidence 0.99):
"[C]c: Amlcompliance In[q]uiries; Rodriguez; Andrew; [S]ubject: Inquiry Regarding Account"
The Zbynek Kozelsky / Southern Financial Connection
EFTA01369043 (confidence 0.98):
"Zbynek Kozelsky; [EFTA016]1 Southern Financial; Dav[ide-A Sferrazza]"
This links Kozelsky -- the PWM team member who received the URGENT THIRD REQUEST emails about the Haze Trust -- directly to Southern Financial LLC, another Epstein shell company. The same person managing the compliance inquiry response was also managing multiple Epstein entities.
The Account Closure Urgency (Late 2018)
Multiple documents reveal a frantic account closure process:
EFTA01372547 (confidence 0.99):
"Dawn Forbes; [S]ubject: URGENT!!! Need to close accounts ASAP - please prio[ritize]"
EFTA01376270 (confidence 0.99):
"Darren Indyke; Stewart O[ldfield]; [Ba]nk accounts closing"
EFTA01379375 (confidence 0.85):
"[T]he CIB offboard list; Clie[nt]"
This timeline aligns with the massive drawdown from the Haze Trust ($49.5M to $7.7M) in the same period.
XI. RECONSTRUCTED PAGE ANALYSIS
Highest-Interest Reconstructed Pages Mentioning Haze Trust
From reconstructed_pages table (sorted by interest_score):
| EFTA | Score | Document Type | Key Content |
|---|---|---|---|
| EFTA01427435 | 43.92 | FINANCIAL | "DARREN K INDYKE PLLC D 193,270.72; THE HAZE TRUST D 21,077,720.73; LARGE TRANSACTIONS; If need help please contact [email protected]" |
| EFTA01427866 | 41.18 | FINANCIAL | Full balance report with Haze Trust, Southern Financial, Butterfly Trust |
| EFTA01427976 | 36.00 | FINANCIAL | "THE HAZE TRUST D 7,717,706.44; SOUTHERN TRUST COMPANY INC M 9,909,230.55; LARGE TRANSACTIONS; SOUTHERN TRUST COMPANY INC 1,000,000.00 MONEY TRANSFER" |
| EFTA01386360 | 15.40 | PHONE_RECORD | "Fax: 646-259-3255; Rodriguez; Shoshan; RE: URGENT THIRD REQU[EST]; WM AMLCompliance; Donald Summer; Regarding THE HAZE TRUST Accou[nt]" |
The reconstructed pages confirm a $1,000,000 MONEY TRANSFER from Southern Trust Company, Inc. flagged as a "LARGE TRANSACTION" in the same report containing The Haze Trust balance (EFTA01427976).
XII. THE VOLCKER RULE CONNECTION
EFTA01407040 reveals a connection to Volcker Rule compliance:
Page 0:
"[Sub]ect: RE: Volcker; USPWM KYC"
Page 1:"For 'The Haze Trus[t]'"
The Volcker Rule restricts proprietary trading by banks. The fact that The Haze Trust appeared in a Volcker Rule review context suggests the trust may have been involved in investment activities that triggered additional regulatory scrutiny -- scrutiny that, based on the evidence, did not lead to meaningful action.
XIII. ANALYTICAL CONCLUSIONS
Was Deutsche Bank's AML Process Genuine or Performative?
Based on the totality of evidence recovered from these redacted documents, the AML process applied to The Haze Trust was overwhelmingly performative. The evidence supports this conclusion on multiple grounds:
1. The "URGENT - THIRD REQUEST!!!!!" Pattern
An AML compliance team that has to send five-exclamation-mark URGENT emails three or more times to get basic account information from its own colleagues is a compliance team that has been structurally disempowered. The PWM team controlled the relationship and the revenue; the compliance team was generating paper, not exercising oversight.
2. The "Please Clear the Alert" Response
EFTA01360448 demonstrates the institutional response pattern: when an AML alert fires, the first instinct is not to investigate but to provide a narrative for clearing the alert. "Richard Kahn is the authorized signer, please clear" is not an AML response -- it is an AML dismissal.
3. The $41.7 Million Drawdown Without a SAR
Between June 2018 and late 2018, approximately $41.7 million was withdrawn from the Haze Trust. This is precisely the type of rapid, large-scale movement of funds that AML systems are designed to detect and report. No SAR was filed.
4. SARs Filed Only After Arrest
The first Epstein SAR was filed on August 9, 2019 -- over a month after his July 6, 2019 arrest. The Maxwell SARs followed in June 2020. This is reactive reporting triggered by media attention and law enforcement action, not proactive compliance.
5. The Duration of the Relationship
The Haze Trust had statements going back to at least February 2011. The AML inquiry (Alert# SAM 1788880) was not initiated until 2017-2018, at the earliest. For 6+ years, an account that would grow to hold nearly $50 million operated without triggering a formal AML inquiry.
6. Overlapping Roles
The same PWM personnel (Kozelsky, Oldfield, Shoshan) managing the Epstein relationship were the recipients of AML compliance inquiries. There was no independence between the revenue-generating function and the compliance-response function. Kozelsky was simultaneously managing Southern Financial LLC and responding to Haze Trust AML inquiries.
7. The FinCEN CDD Rule Implementation
DB was implementing FinCEN's Customer Due Diligence rule during the same period as the Haze Trust inquiry. The CDD rule required identifying beneficial owners of legal entities. The Haze Trust -- a trust with Richard Kahn as signer, holding $49 million, controlled by a convicted sex offender -- was precisely the type of entity the CDD rule was designed to scrutinize.
The Compliance Theater Model
The evidence paints a picture of a three-act compliance theater:
Act I: The Alert -- AML systems generate an alert (SAM 1788880) based on monitoring systems. The system works as designed.
Act II: The Inquiry -- Compliance sends inquiry emails to PWM. PWM delays, ignores, or provides minimal responses. Compliance escalates to "URGENT - THIRD REQUEST!!!!!" The emails generate a paper trail showing "compliance tried."
Act III: The Resolution -- Either the alert is cleared with a minimal explanation ("Richard Kahn is the authorized signer"), or the inquiry trails off without resolution. No SAR is filed. The account remains open. The revenue continues.
This model persisted for the duration of the Epstein relationship. It was not until external forces (arrest, prosecution, media scrutiny) intervened that DB took the step of filing SARs -- and even then, the $30.7 million figure referenced in EFTA01648786 suggests the SARs significantly understated the true scope of suspicious activity.
XIV. EVIDENCE INVENTORY
Primary Documents (Confidence >= 0.99)
| EFTA Number | Document Type | Key Content |
|---|---|---|
| EFTA01357853 | AML Inquiry Origin | Stepanian + AML Compliance + Haze Trust inquiry initiation |
| EFTA01369019 | Full Alert Identification | Account# N4G024943, Alert# SAM 1788880 |
| EFTA01369002 | URGENT THIRD REQUEST | Escalation with full recipient list |
| EFTA01369003 | Email Thread | Rodriguez, Stepanian, Shoshan, AML Compliance |
| EFTA01369004 | Reply Thread | Shoshan reply re: Haze Trust inquiry |
| EFTA01369017 | Internal Escalation | PWM AML + URGENT THIRD REQUEST |
| EFTA01381149 | Balance Consolidation | Complete Epstein entity list, 08/17/18 |
| EFTA01381246 | Balance Report | Peak balance $49,460,098.13, 06/21/18 |
| EFTA01413743 | Multi-page Thread (11pg) | Full inquiry correspondence with Quigley escalation |
| EFTA01414223 | Multi-page Thread (10pg) | Extended Haze Trust inquiry with all parties |
| EFTA01414241 | Multi-page Thread (17pg) | URGENT THIRD REQUEST with SAM1788880 reference |
| EFTA01423476 | Multi-page Thread (12pg) | Late-stage inquiry with compliance distribution |
| EFTA01430852 | Balance Report | Haze Trust $49,233,909.70 |
| EFTA01431991 | Balance Report | Dual Haze Trust entries: $2.5M + $12.7M |
| EFTA01649596 | SAR Filing | Epstein SAR - August 15, 2019 - "Crimes Against Children" |
| EFTA01654078 | SAR Discussion | Epstein SAR - August 9, 2019 |
| EFTA01660736 | SAR with NYPD/FBI | SAR coordination with law enforcement |
Total Evidentiary Scope
- 300 unique EFTA documents referencing The Haze Trust
- 207 Haze Trust bank statements (2011-2013 range)
- 11 documents referencing Alert# SAM 1788880
- 100+ documents referencing Vahe Stepanian
- 6 Epstein SAR-related documents (all post-arrest)
- 15+ connected Epstein entities identified in consolidation reports
XV. RECOMMENDATIONS FOR FURTHER INVESTIGATION
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Fund Flow Tracing: The $41.7 million drawdown (June-December 2018) should be traced through wire transfer records to identify receiving accounts and jurisdictions.
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Timing Analysis: The precise date Alert# SAM 1788880 was triggered should be established. If it was triggered before 2017, the delay in escalation becomes even more significant.
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Richard Kahn's Role: Kahn's role as trustee and "sole authorized signer" of the Haze Trust should be cross-referenced with his roles in other Epstein entities (he also appears in connection with other trusts per EFTA01423752).
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Southern Financial LLC: Kozelsky's simultaneous management of Southern Financial LLC and involvement in the Haze Trust AML response represents a potential conflict of interest requiring further examination.
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The $30.7 Million SAR: EFTA01648786 references "$30.7 million for Epstein" in connection with SARs. This figure should be reconciled against the $49.5 million peak balance to determine whether DB underreported to FinCEN.
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Butterfly Trust Connection: The Butterfly Trust consistently appears alongside the Haze Trust in balance reports. Its beneficial ownership structure and fund flows between the two trusts should be mapped.
XVI. FINAL ASSESSMENT
The Haze Trust AML inquiry at Deutsche Bank represents a systemic failure of anti-money laundering controls at one of the world's largest financial institutions. The evidence recovered from these redacted documents demonstrates that:
- DB's AML systems did detect suspicious activity (Alert# SAM 1788880)
- DB's compliance team did attempt to investigate by questioning the PWM banking team (Stepanian, Morris, Oldfield, Kozelsky), but the banking team systematically deflected. Note: Stepanian was not a compliance officer but the PWM team member being questioned by compliance.
- DB's private wealth management team systematically obstructed the compliance process (requiring URGENT THIRD REQUEST escalations)
- DB's institutional response was to clear alerts rather than file SARs
- DB did not file a Suspicious Activity Report until weeks after Epstein's arrest
- During the AML inquiry period, approximately $41.7 million was withdrawn from the Haze Trust without triggering a SAR filing
- The same personnel managing the Epstein relationship were responsible for responding to compliance inquiries about that relationship
This is not a case of AML systems failing to detect suspicious activity. It is a case of an institution that detected suspicious activity and chose not to act on it -- a pattern consistent with the prioritization of client revenue over regulatory compliance obligations.
The Haze Trust, holding nearly $50 million at its peak (within a total Epstein relationship of $230-330 million), was the single largest account in an intricate web of shell companies controlled by a convicted sex offender. That it operated at Deutsche Bank for 20 years (1999-2019) without a proactive SAR filing is not a compliance gap. It is a compliance failure of the most fundamental kind.
APPENDIX E: DS9/DS11 REVISIT FINDINGS (2026-02-12)
DS9/DS11 full-text search identified 412 unique EFTA documents referencing "Haze Trust" (136 in DS11 alone), representing a substantial expansion beyond the original 300 DS10-based documents.
Key DS9 Corrections Applied Above
- Formation date: February 9, 1999 (not 1991 OCR artifact); trust operated 20 years, not ~8
- Stepanian role: PWM team member, not AML compliance officer
- Total relationship: $230-330M, not ~$49M
- Ownership chain: HAZE TRUST (EIN 13-7185414) is a grantor trust of Southern Financial LLC, which is a disregarded entity 100% owned by Southern Trust Company, Inc. (EFTA00593861)
Key DS9 New Documents
| EFTA | Description |
|---|---|
| EFTA00128968 | FBI FD-302: Cherie Quigley -- "maybe a SAR should have been filed on EPSTEIN" |
| EFTA00128765 | FBI FD-302: Amanda Kirby -- Morris "insecure and a back-handed manipulator," MC2 wires "did not raise a red flag" |
| EFTA00080250 | SDNY Exhibit D: complete Haze Trust transaction tables with DB-SDNY Bates numbers |
| EFTA00168946 | Complete KYC Print (20 pages): Haze Trust rated "Overall-HIGH, Entity-HIGH, Industry-HIGH, Country-MEDIUM, Product-HIGH" |
| EFTA00166763 | Complete KYC Print (12 pages): full risk profile for Epstein Jeffrey Relationship |
| EFTA00144222 | FBI objected to FinCEN SAR release in 2023 civil litigation, citing pending Maxwell appeal |
| EFTA00090637 | JPMorgan filed 14 SARs and 89 CTRs on Epstein -- a parallel SAR filing DB apparently never cross-referenced |
| EFTA00313328 | Christie's Seller Agreement for Haze Trust -- "Post-War and Contemporary Art Evening Auction" (Dec 2017) |
| EFTA01255683 | Full trust agreement with signature pages, successor trustee designation |
| EFTA00076491 | Estate Verified Inventory: Southern Trust Company Inc. valued at $233.6 million |
This report was generated through forensic analysis of 1,808,915 redacted text fragments, 107,422 extracted entities, and 39,588 reconstructed pages from the DOJ Epstein Files database, supplemented by DS9/DS11 full-text corpus review (862,939 documents). All quoted text is reproduced exactly as extracted from document text layers (OCR), with brackets indicating reconstructed characters where OCR confidence was below 0.99. DATA QUALITY NOTE: A data quality audit confirmed ~98% of 'bad_overlay' records are OCR noise from degraded scans. Text searches remain valid for identifying document content.