Amanda Kirby

⚠ what this page is about, and what it is not

The Deutsche Bank associate who ran the paperwork on Epstein’s trust and entity accounts, and whose own e-mails record the bank’s compliance function rejecting that paperwork. No allegation against her was found anywhere in the release, and none is made here. ⚠ A rejected KYC file is a control working; what this page documents is what happened around the rejections.

Who	Amanda Kirby, Associate, Deutsche Bank Trust Company Americas, 345 Park Avenue, New York, per her own signature block1
In the release	6,193 documents2
Her own messages	2,153 sender rows across 1,747 documents, 11 March 2013 to 24 May 20162
⭐ The document, 7 Oct 2013	An AML compliance officer’s automated notice: “Your KYC has been rejected.” Relationship “EPSTEIN, JEFFREY RELATIONSHIP”, customer “Butterfly Trust”3
⚠ Why it was rejected	”Since this is an Irrevocable Trust, following needs to be done for the beneficiaries: i: Name and address ii: RDC & PCR searches (excluding minors)” and “Please complete Wealth Profile for Butterfly Trust”3
⭐ 13 Dec 2013	With the compliance officer out of the office, she asks two colleagues to clear a rejection: “there is no negative information. Not on the research report nor when I Google her name.” and “This is my last day before I leave for my MTA so would like to get this resolved this morning so I can open the account this afternoon.”4
Scale of it	110 of her messages carry KYC in the subject line2

What a rejected KYC looked like inside the bank

On 7 October 2013 an automated notice went to her from the bank’s Private Wealth Management AML compliance function. It is headed “Your KYC has been rejected.” and carries a case number, the relationship name “EPSTEIN, JEFFREY RELATIONSHIP” and the customer name Butterfly Trust. Two things were missing: the beneficiaries of the trust had not been named, addressed and screened, and no wealth profile had been completed.³

⚠⚠ ON THE PHRASE “excluding minors”. It appears in the rejection as a carve-out in a screening instruction: it says which beneficiaries must be run through the bank’s database searches. ⚠ NO DOCUMENT READ FOR THIS PAGE STATES THAT ANY BENEFICIARY OF THIS TRUST WAS A MINOR, and the desk draws no inference from a line of standing compliance boilerplate. It is quoted because the reason for rejection is quoted whole.³

Her exchange with the compliance officer the same afternoon is a junior banker checking she has understood the rule before going back to the client:

Just called to ask you a quick question. Why do we need the addresses for the beneficiaries of an irrevocable trust and not a revocable trust if there are no distributions? I want to make sure I fully understand the answer before I reach out to the client for the beneficiary addresses. I have no doubt he’ll ask!

⚠ “he’ll ask” is the nearest thing on the sheet to a characterisation of the client, and it is left to stand as written.³

13 December 2013: clearing a rejection on the last morning

Two months later she wrote to two colleagues at 09:30, copying Paul Morris:

I just saw that Jacqueline is out of the office today. Can you please help with this KYC issue? Jacqueline rejected one asking for AML clearance for negative information regarding our client but there is no negative information. Not on the research report nor when I Google her name. Below is her research report and the KYC # is ▮▮▮ This is my last day before I leave for my MTA so would like to get this resolved this morning so I can open the account this afternoon. Very much appreciate your help

Two minutes later she followed up: “Apologies. Research attached here”.⁴

⚠⚠ WHAT THIS DOES AND DOES NOT DOCUMENT. It documents a banker asking colleagues to resolve a compliance rejection the same morning, on her last day before leave, so that an account could be opened that afternoon. It does not document that the rejection was overridden: no document read for this page records what the two colleagues did, or whether the account opened. ⚠ The client in this thread is a woman whose name is redacted on the sheet. The desk did not attempt to identify her, and no inference about her is offered.

⚠ The sheet bears a grand-jury legend, “CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)”, alongside a Deutsche Bank production stamp and an SDNY stamp: this message travelled from the bank into a federal criminal investigation.⁴

What the rest of the traffic is

110 of her messages carry KYC in the subject. Recurring subjects include “Past due KYC temporary exception”, “NES, LLC. KYC #: …” and numbered KYC cases; elsewhere her traffic runs on “Euro Request”, “Additional signer”, “ACATS for Southern Financial/Trust”, “Wire instructions” and “Case #… :Gratitude America”. ⚠ The desk opened two of these documents. It did not open the others and does not characterise them.²

What this page does not say

No allegation against her was found anywhere in the release.⁵

⚠⚠ NOTHING HERE SUGGESTS SHE DID ANYTHING IMPROPER. She is an associate executing onboarding paperwork, asking compliance to explain its own rule, and chasing a decision before going on leave. ⚠ Whether Deutsche Bank’s controls were adequate is an institutional question and belongs at Deutsche Bank, not to any individual named here.

Related

• Deutsche Bank
• Butterfly Trust
• Paul Morris
• Daniel Sabba
• Southern Financial, LLC
• NES, LLC

Footnotes

Footnotes

1. Identification. Title and employer are taken from her own signature block as it prints on EFTA01404859 p.3: Amanda Kirby / Associate / Deutsche Bank Trust Company Americas / 345 Park Avenue, 27th Fl / New York, NY, USA, 10154-0004. ⚠ Telephone, fax and e-mail are redacted on the sheet and are not supplied from any other source. The address printed here is a bank office floor, not a residence. ↩

2. The measurement. "Amanda Kirby" returns 6,193 documents. ⚠ The hinge is page scope: a document counts when any one of its pages carries the phrase, and a distribution list counts. In the e-mail metadata store she is the normalised sender of 2,153 rows across 1,747 documents, 11 March 2013 to 24 May 2016; a looser match on the sender string returns 2,754 rows, and the gap between the two is not investigated here. 110 of the loose rows carry KYC in the subject, the largest single groups being Fw: Your KYC has been rejected (17) and Re: Your KYC has been rejected (14 plus 7 with an [I] marking). ⚠ No doc_type figure is printed, under the rule in _desk/TOOLS.md: the classifier measured 100% on email.header but 52% and 5% on two other labels, so any other label must be spot-checked before it reaches a page. ⚠ No deduplicated message total is stated. ↩ ↩² ↩³ ↩⁴

3. 7 October 2013. EFTA01404859, a three-sheet chain; p.3, whose own page stamp reads EFTA01404861, was rendered and read at the image at 700 dpi. The rejection notice prints Your KYC has been rejected. above Case #: 01133113, Relationship: EPSTEIN, JEFFREY RELATIONSHIP, Customer Name: Butterfly Trust, the reason for rejection quoted above, and a link into the bank’s case system. ⚠ A customer number prints beside those lines and is NOT reproduced here, under the desk’s standing bar on account and customer identifiers. The sender of the notice is named on the sheet as an AML Compliance Officer and her exchange with Kirby on pp.1-2 is quoted from the text layer of the same document; those two sheets were not separately rendered, and the quotation from p.1 is marked as such. ⚠ The [I] and [C] markings in the subject lines are the bank’s own and are not expanded, because no document read here expands them. ↩ ↩² ↩³ ↩⁴ ↩⁵

4. 13 December 2013. EFTA01360379 p.1, read at the image at 700 dpi, Re: Fw: Your KYC has been rejected, sent 12/13/2013 9:32:37 AM, quoting her own message of 12/13/2013 09:30 AM. The double spaces are as printed. ⚠ The text layer reads “MIA” where the image reads “MTA”; the image governs, and the desk does not expand the abbreviation. ⚠ The KYC number is redacted on the sheet and is shown as ▮▮▮. A completed redaction is not filled in by this desk. ⚠ A research report is attached and is not in this document; nothing on this page describes its contents beyond her own characterisation of them. The sheet carries CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) with the production stamps DB-SDNY-0048691 and SDNY_GM_00194875. ↩ ↩² ↩³

5. Absences, each scoped. No allegation against her was found in the release read for this page. ⚠⚠ This is a narrow check against 6,193 documents and is stated as one: the desk opened two documents. It ran no systematic adverse sweep, searched none of the six derived stores, and opened none of the other 108 KYC-subject messages. ⚠ A deeper pass is owed, and this page records the debt rather than implying it does not exist. ↩