Epstein Data Wiki

Andrew Gallivan

Properties2
tagsperson, deutsche-bank, kyc, approvals, southern-financial, negative-media, 2015, 2019
aliasesAndrew Gallivan, Andrew F Gallivan, Andrew F. Gallivan, Gallivan, Andrew

23 min read

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

The Deutsche Bank business head who approved keeping Jeffrey Epstein as a client. He is the “Andrew” of the fourth question the bank’s divisional control officer put in writing on 22 October 2018, and the release contains his answer. No allegation against him was found anywhere in the release, and none is made here. Everything below is an internal bank approval recorded in an internal bank document. ⚠ What he reviewed before approving is not recorded in anything read for this page.

WhoAndrew F Gallivan, Deutsche Bank Trust Company Americas. His own signature block of September 2017 gives “Global Products & Solutions”1; the bank’s KYC approval forms record him in the row “Office Director/Business Head”2
In the release664 documents carry the token Gallivan. One of them is a different person (see below). Duplicate copies of the same message are not collapsed in that figure3
His own messages125 sender rows across 109 documents, 21 February 2014 to 31 January 2019. 636 rows address him in a To or Cc line3
He is at the head of the first sheet in42 of the 664 documents: 6.3% of the population, 8.5% of the 494 whose first sheet carries any sender label at all3
⭐ The act, 13 Nov 2018”Based on the below I approve continuing this relationship”4
⭐ The act, 10 Oct 2018”Approved”, thirteen minutes after being asked for “Business approval” to raise Epstein’s daily wire limit to $20mn5
⭐ The act, 7 Apr 2017”Approved.”, the monthly managing-director sign-off on completed annual client updates for high-risk clients, the schedule to it carrying twelve Epstein-related customer records6
⚠ What he was asked”Andrew — please confirm that you remain comfortable with the business risk here.”4
⚠⚠ How the control officer recorded his answer”I received the below email from Andrew Gallivan confirming his comfort with continuing the Epstein relationship.”4

The question that names him

On 22 October 2018 at 2:30 PM the bank’s divisional control officer, Kimberly Hart, put four numbered questions to Richard Iarossi about Epstein’s connection to the Towers Financial matter. The fourth asked whether “Andrew” had reviewed the information and was comfortable maintaining the relationship. The four questions are quoted and treated in full at Stewart Oldfield, and the thread that produced them at Kimberly Hart; they are not restated here.

What is new here is one line of that sheet’s own header. The message is copied to Andrew Gallivan by name, alongside Bradley Gillin and Oldfield. So the man the question asks about is a named recipient of the question.7

13 November 2018: the answer

Sixteen days later, on 7 November at 5:12 PM, Oldfield sent Gallivan and Hart a six-paragraph account of the lawsuit, said it came “based on a conversation with Jeffrey’s lawyer”, and put the request directly:

Andrew — please confirm that you remain comfortable with the business risk here.

Kim — please forward as necessary

On 13 November 2018 at 10:38:04 AM, under “Classification: Confidential”, Gallivan replied to Oldfield and Hart, copying Gillin and Iarossi, with a single line:

Based on the below I approve continuing this relationship

⚠ The sheet carries no full stop after “relationship” and nothing else in the body. The whole message is that sentence and his name.4

The next morning, 14 November at 8:16:36 AM EST, Hart forwarded the thread to two AML Compliance colleagues and characterised what she had received:

I received the below email from Andrew Gallivan confirming his comfort with continuing the Epstein relationship. I do not see any new allegations that have not been previously considered and risk accepted. The recent lawsuit appears to be unfounded and was promptly withdrawn. Please let me know if you are seeing something additional that should be considered and escalated. Otherwise, I think that we can proceed based on the previous clearance.

⚠⚠ That sentence is what closes the identification. The question of 22 October asked whether “Andrew” was comfortable maintaining the relationship; the control officer who wrote it records, three weeks later, receiving an email from Andrew Gallivan confirming his comfort with continuing the Epstein relationship. The desk does not have to infer which Andrew was meant. The control officer wrote his surname.4

And the approval reached the KYC production line the next day. At 03:52 on 15 November a KYC case representative in the bank’s Mumbai centre replied to Oldfield: “We have submitted a few rejection cases from the Southern Financial Relationship based on the below approval.”4

⚠⚠ What the approval does not establish, stated at the same weight

  • No document read for this page records what Gallivan reviewed. Question (4) had two limbs, “has Andrew reviewed the information” and “is he comfortable”. His reply answers the second in seven words and says nothing about the first beyond “Based on the below”, which points at Oldfield’s summary and at nothing else.
  • No answer from him to questions (1), (2) or (3) appears in anything read here. Those were addressed to Iarossi, not to him.
  • Oldfield’s summary is the evidence Gallivan says he relied on, and it is secondhand. Its own first line attributes it to “a conversation with Jeffrey’s lawyer”. The notice of dismissal it refers to is an attachment and is not in this document.
  • Nothing read here records the bank acting on the approval beyond the Mumbai reply above.

10 October 2018: the $20mn wire limit

Twelve days before Hart’s four questions were written, and the day after the negative-media review began, Iarossi wrote to Gallivan at 10:32 AM:

Jeffrey Epstein has asked to raise his daily wire limit to $20mn. We have received Product approval below and now require Business approval.

Please review at your convenience.

At 10:45:29 that morning Gallivan replied “Approved”, copying Gillin and Oldfield, under “Classification: For internal use only”. Thirteen minutes elapsed between the request and the approval.5

The product-side approval quoted beneath it, from a director in the product team, had already named him as the person whose sign-off was still needed: “I approve of the wire limit for Product. You also need a business lead (e.g., Andrew Gallivan) to a pprove.” The broken word is the sheet’s own line break and is transcribed as it appears.5

⚠ The form being approved is an attachment and is not in this document, and nothing read for this page records whether the limit was in fact raised. The earlier sheets of the same request are treated at Richard Iarossi.

7 April 2017: the monthly sign-off, and what was on the schedule

Under a policy the sender describes on the sheet, “the new Policy now requires an MD Approval over and above the approval of the account owner / RM”, a KYC analyst sent Gallivan the month’s completed annual client updates for high-risk clients. On 7 April 2017 at 15:15:31 he replied “Approved.”6

The schedule attached to that request runs to eighteen further sheets. On the sheets read at the image, the following customer records are listed with Andrew Gallivan in the MD field, 3/16/2017 as the update date and Stewart Oldfield as the customer owner:

Customer record on the scheduleStatus text on the sheet
Butterfly Trust”change in beneficiaries” / “No material change”
HBRK Associates, Inc”No material change”
Hyperion Air, LLC”no material change”
JEGE, Inc (listed twice, under two record numbers)“no material change”
JEGE, LLC”No material change”
one customer name blacked out by the producing party”no material change”
Neptune, LLC”no material change”
NES, LLC”No material change”
Plan D, LLC”No material change”
Southern Financial LLC”No changes in activities.” / “No changes”
Southern Trust Company, Inc.”Southern Trust is still a private investment company and has not had any changes”
The 2007 Jeffrey E. Epstein Insurance Trust #3”No material change”

That is twelve customer records in one block, all with the same MD, the same date and the same customer owner.6

⚠ Two cautions about this table. First, the schedule is not a multi-column table in the produced PDF: each field is on its own line, in row order, so the column-interleaving hazard that has misled this desk before does not arise here, and that was checked at the image rather than assumed.6 Second, the same schedule lists many customers with no connection to Epstein, including private individuals; those rows are not reproduced here and were not read closely. Customer numbers appear beside every row on the sheet and none is reproduced on this page.

8 February 2018: a new Epstein trust, approved at his row

A “KYC Print” of ten sheets covers The 2017 Caterpillar Trust, described on its face as a new client whose ultimate beneficial owner is Jeffrey Epstein. Its case comment repeats almost word for word the formula the bank had used the previous summer, including the passage about negative media and the client’s closeness to Bill Clinton and Prince Andrew that is quoted at Bill Clinton.

The ONSHORE APPROVALS block records “stewart oldfield” as Client Facing Professional, dated 2/8/2018, and “Andrew F Gallivan” as Office Director/Business Head, dated 2/8/2018. The Regional Office Director and AML Business Risk rows are empty. AML Compliance carries two names dated 2/13/2018.2

⚠⚠ This is not a signature. Every entry in the block is machine-printed type in a system-generated print, the form’s own footer showing the database URL it was printed from and a print date of 7/11/2019. What the document records is that the system holds his approval against that row on that date. It does not show a mark made by a hand. The same caution is stated on the 2017 form quoted at Bill Clinton.

The bank’s KYC approval blocks are not rare, and his name is on a lot of them. The phrase Office Director/Business Head appears in 118 documents in the release; 32 of them also carry the token Gallivan and two more carry the single-l misreading Galivan. ⚠ That is a document-level co-occurrence and a floor, not a count of approvals. One of those blocks was read at the image for this page; a second, of July 2017, is recorded as read at the image at Bill Clinton. The other thirty were not opened.3

How he became the man the question was addressed to

November 2015. Epstein asked to change his coverage team. Paul Morris wrote to Chip Packard, co-head of Wealth Management Americas, that “JE called, he requested coverage change”. Packard replied within the hour: “I am sandwiched today and this needs immediate attention so please take up with Gallivan and keep me in the loop.” Half an hour later he added: “Please start with Andrew as we should address this soon.” Gallivan’s own reply, on 16 November, is a scheduling line and nothing more.8

December 2016. When a high-risk rush KYC case for a newly created Epstein entity needed executive-committee approval, the business-line head and Hart were asked to recall whether the name had been to a risk committee. Hart’s reply is addressed to Patrick Campion and to Gallivan. ⚠ He is in a copy line there and no act by him is recorded on that sheet. The document is cited for a different reason at Jared Kushner.9

September 2017. Gallivan opened a thread with the head of business risk management with the line “I need to give an update for the DBTCA Board and thought we should be consistent”, then worked through the bank’s handling of high-risk and medium-risk KYC files: “Send me the full list and we can pull the DB Trusts”; “Yes let’s get that going I can get David Ed et al up to speed and let’s get this rolling”. ⚠⚠ Nothing in that thread is about Epstein. It is cited only for what it establishes about his position: he reported to the board of Deutsche Bank Trust Company Americas on high-risk KYC, and the whole moderate-risk trust population under discussion ran to 392 clients.1

December 2018. A meeting under the subject “Epstein discussion” was arranged and Gallivan returned a calendar acceptance on 12 December. ⚠ A calendar acceptance is evidence that a meeting was arranged, not that it took place, and nothing read here records what was said.10

Name forms, and the one Gallivan who is not him

⚠⚠ The two full-name forms in this release do not overlap at all.

Form queriedDocuments
"Andrew Gallivan"594
"Andrew F Gallivan"44
both forms in the same document0
union of the two638
bare surname Gallivan664

Forty-four documents carry only the middle-initial form and 594 only the plain form. A pass keyed on either alone loses the other entirely. The corpus tokeniser splits on the full stop, so "Andrew F. Gallivan" and "Andrew F Gallivan" are one query and not two corroborating forms.3

The surname reaches 26 documents that neither full form reaches. Read, they are: copy lines and schedules where his forename is separated from his surname by the extraction; two KYC approval blocks where the text layer renders the name “Mdrew F Gallivan” and “Andrew F Caravan”; one where it welds the block to “AndrewGalivan”; and one document that is a different person altogether, a Virgin Islands court item naming an attorney, Jessica Gallivan, appointed to the St. Croix Division and described as the chief labor negotiator for the Office of Collective Bargaining. That is the only document of the 664 that is not about the Deutsche Bank officer.3

What this page does not establish

  • No allegation against Gallivan was found anywhere in the release. Gallivan co-occurs with "grand jury", deposition, subpoena and "consent order" in zero documents. That is a statement about four FTS conjunctions run over the corpus text layer, not a statement about the world.11
  • Nothing read here records him meeting Epstein, corresponding with Epstein, or being paid by Epstein. Every act on this page is an internal bank approval.
  • The document count is not a measure of the record. Duplicate copies of the same message are counted separately: the 13 November approval alone survives in eighteen rows of the metadata store. The desk did not deduplicate the 664.3
  • His file stops before the arrest. The last dated message from him in the metadata store is 31 January 2019, five months before Epstein’s federal arrest. Nothing read here covers the bank’s 2019 exit or the regulatory action that followed; those belong at Deutsche Bank.
  • What was NOT opened. The other sixteen or more copies of the 13 November approval; the remaining thirty KYC approval blocks carrying his surname; sheets 13 to 20 of the April 2017 schedule, which list unrelated customers; the 4 December 2018 message setting up an Epstein meeting, which was seen only in the metadata store and not at the image; and all but four of the 109 documents in which he is the top-level sender.

Footnotes

  1. 8 to 12 September 2017. EFTA01398709 p. 8, and pp. 1 to 9 generally. Nine sheets, page stamps EFTA01398709 to EFTA01398717, subject What are you presenting to the Risk committee Monday on high risk KYC's [I]. Read at the text layer only; no sheet of this document was rendered. Gallivan’s opening message of Friday, September 08, 2017 9:53 AM is on p. 8, his signature block there giving the division name quoted above; his later messages are on pp. 7, 6, 5 and 3. The figure of 392 moderate-risk trust accounts is on p. 3, in a message from a colleague. ⚠⚠ Nothing in this chain concerns Epstein, and it is cited only for what it records about his position. ⚠ Telephone and fax values belonging to a third party are present on several sheets of this run and none is reproduced here. ↩ ↩2

  2. The 2017 Caterpillar Trust KYC Print. EFTA01282185 p. 9, headed “KYC Print” and “Page 9 of 10”, rendered and READ AT THE IMAGE at 700 dpi; the text layer of that sheet renders the row as “Office Deector/Business Head: Mdrew F Gallivan” and its signature cell as “Mdrew F Gallivan 2/8/2018”. The clean form of the label is read off the image and will not be found in this document’s text layer, so a phrase checker will report it unresolved; the damaged renderings are given here so that it has something to bind. At the image the ONSHORE APPROVALS block records the Client Facing Professional as “stewart oldfield”, dated 2/8/2018, and the Office Director and Business Head row as “Andrew F Gallivan”, dated 2/8/2018, with the Regional Office Director and AML Business Risk rows blank and AML Compliance carrying two names at 2/13/2018. Every one of those entries is printed type, not ink; the sheet’s footer carries the database URL it was printed from and a print date of 7/11/2019, and the sheet is marked “CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)”. The case-comment dates print as “3/16/118”, “2/13/118” and “2/8/118” on the face of the sheet, the same three-digit year quirk recorded on the 2017 form cited at Bill Clinton. ⚠ Only p. 9 of this ten-sheet run was opened. ↩ ↩2

  3. Counting method, and the queries as run. Document counts are distinct efta_number values over the page-level FTS index of the full-text corpus, queried over HTTP on 20 September 2026: "Andrew Gallivan" 594, "Andrew F Gallivan" 44, intersection 0, union 638, bare token Gallivan 664, Galivan 16, "Jessica Gallivan" 1, "Office Director Business Head" 118, that phrase with Gallivan 32 and with Galivan 2. The tokeniser is unicode61 and splits on the full stop and the solidus, so "Andrew F. Gallivan" and Office Director/Business Head are reached by the forms printed here. Sender and recipient figures are rows in the release’s e-mail metadata store: sender like '%Gallivan%' returns 125 rows across 109 documents, of which 124 carry a date, running 21 February 2014 to 31 January 2019; a To or Cc line matching the same string returns 636 rows. The act rate was computed by this desk over the whole 664-document population, not sampled: the first sheet of each document was fetched, the first sender label on it located with the desk’s seventeen-form anchored pattern, and the value tested for his surname. 494 of 664 first sheets carry any sender label at all; 42 carry his. 42/664 = 6.3% of the population and 42/494 = 8.5% of the documents with a sender. ⚠ A document count is not a count of distinct items. The 13 November approval alone appears in eighteen rows of the metadata store under ten different renderings of one subject line, and no deduplication was performed. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  4. 9 October to 15 November 2018. EFTA01425564 p. 1, p. 3, p. 4 and p. 5. An eight-sheet chain, page stamps EFTA01425564 to EFTA01425571, and the copy that carries the whole exchange from Oldfield’s first message of 9 October to the Mumbai reply of 15 November. Rendered and READ AT THE IMAGE at 700 dpi: p. 1 (Vijay-A Sawant, Thu, 15 Nov 2018 03:52:43 -0500), p. 3 (Kimberly Hart, November 14, 2018 at 8:16:36 AM EST) and p. 4 (Andrew Gallivan, Tuesday, November 13, 2018 10:38 AM). Sheets 2 and 5 to 8 of this run were read at the text layer only. A second copy, EFTA01418351, five sheets, was independently rendered and READ AT THE IMAGE at 700 dpi at p. 1 and p. 2: its p. 1 carries Gallivan’s message as a top-level header with the full stamp Date: Tue, 13 Nov 2018 10:38:04 -0500, and its p. 2 is where Oldfield’s 7 November message was read at the image, the same text that sits at p. 5 of the eight-sheet copy pinned above. The double spaces inside the quotations are as printed, and the dashes inside quoted lines are the sheets’ own. ⚠ The text layer of several copies renders the subject line as Epstein - ne ative media; the image reads Epstein - negative media. ⚠ Header address values and the telephone, fax, mobile and e-mail fields under every signature block on these sheets are blacked out by the producing party, and no contact value from any of them is reproduced here. ⚠ The attachment referred to on 18 October, a notice of dismissal dated 10/5/18, is not in either document. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  5. 5 to 10 October 2018. EFTA01431586 p. 1, rendered and READ AT THE IMAGE at 700 dpi. A three-sheet chain, page stamps EFTA01431586 to EFTA01431588, subject Wiring limit increase[I]; pp. 2 and 3 were read at the text layer only. Every quotation above is transcribed from the image of p. 1: Gallivan’s Date: Wed, 10 Oct 2018 10:45:29 -0400 reply; Iarossi’s request of Wednesday, October 10, 2018 10:32 AM; and Arthur Tremblay’s product approval of Wednesday, October 10, 2018 9:56 AM, which reads at the image “I approve of the wire limit for Product. You also need a business lead (e.g., Andrew Gallivan) to a pprove.” ⚠ The text layer of this sheet drops the time from Gallivan’s Date: line, printing only Wed, 10 Oct 2018; the image carries 10:45:29 -0400, which is what the thirteen-minute interval is measured from. ⚠ The sheet’s own line break splits “approve” across two lines as to a and pprove, and the damaged form is given above so that a later reader meets it where it occurs. ⚠ A shorter two-sheet copy of the same request, EFTA01423553, is cited at Richard Iarossi; it stops at the product approval and does not carry Gallivan’s reply. ⚠ Contact-value fields are barred on this sheet and none is reproduced here. ↩ ↩2 ↩3

  6. 5 to 7 April 2017. EFTA01398793 p. 1, p. 8, p. 10 and p. 12, rendered and READ AT THE IMAGE at 700 dpi. Twenty sheets, page stamps EFTA01398793 to EFTA01398812, subject MD approval for ACUs completed for High Risk Clients [I]. p. 1 carries Gallivan’s Fri, 07 Apr 2017 15:15:31 -0400 reply, the analyst’s request of Friday, April 07, 2017 2:21 PM, and the covering message of Wednesday, April 05, 2017 12:23 PM carrying the sentence about the new policy. p. 8 carries the Butterfly Trust row’s tail, HBRK Associates and Hyperion Air; p. 10 carries JEGE, LLC, the barred customer name and Neptune, LLC; p. 12 carries Southern Financial, Southern Trust Company and The 2007 Jeffrey E. Epstein Insurance Trust #3. pp. 2 to 7, 9, 11 and 13 to 20 were read at the text layer only. ⚠ The schedule is rendered one field to a line in row order, not as a multi-column table, which was confirmed at the image on pp. 8, 10 and 12 before the rows above were paired. ⚠ A customer number stands beside every row and none is reproduced here. ⚠ On p. 10 the customer name of one record in the same block is blacked out by the producing party, and the desk does not name it. ⚠ pp. 13 to 20 list customers with no connection to Epstein, including private individuals, and are not reproduced or characterised here. ⚠ A truncation checker flags the Southern Trust status text quoted above as ending mid-sentence. It does not: the next line of the extraction is the next FIELD of the record, not the next clause, and at the image on p. 12 that field ends exactly where the quotation ends, with no full stop of its own. The row is an artefact of the one-field-to-a-line layout and no text was cut. ↩ ↩2 ↩3 ↩4

  7. 22 October 2018, 2:30 PM. EFTA01423573 p. 3 (page stamp EFTA01423575), rendered and READ AT THE IMAGE at 700 dpi. The header reads From: Kimberly Hart / Sent: Monday, October 22, 2018 2:30 PM / To: Richard Iarossi / Cc: Bradley Gillin ▮; Stewart Oldfield ▮; Andrew Gallivan ▮ / Subject: FW: Epstein - negative media [I], the ▮ marking address values blacked out by the producing party. The presence of “Andrew Gallivan” in that Cc line was read at the image and not taken from the extraction. The four questions themselves are on the same sheet and are quoted in full at Stewart Oldfield; the seven-sheet chain is treated there and at Kimberly Hart. ⚠ The desk does not expand “TFC” from the sheet, because the sheet does not. ↩

  8. 10 to 16 November 2015. EFTA01475666 p. 1, p. 2, p. 3 and p. 4. Four sheets, page stamps EFTA01475666 to EFTA01475669, subject Southern Financial [C]. Read at the text layer only; no sheet was rendered. Gallivan’s reply of Mon, 16 Nov 2015 15:39:54 -0500 is on p. 1; Chip Packard’s message of Tuesday, November 10, 2015 2:33 PM is on p. 2; his message of Tuesday, November 10, 2015 1:23 PM is on p. 3; and Paul Morris’s message of Tuesday, November 10, 2015 11:09 AM is on p. 4. A second copy of the same chain, EFTA01458804, carries the 10 November messages on a single sheet and renders Morris’s line as “not working with OS” where the four-sheet copy reads “not working with DS”; neither reading has been settled at an image and the initials are not expanded here. ↩

  9. 14 to 15 December 2016. EFTA01398718 p. 1, and pp. 1 to 6 generally. Six sheets, page stamps EFTA01398718 to EFTA01398723. Read at the text layer only for this page. Kimberly Hart’s reply of Thu, 15 Dec 2016 14:14:20 -0500, addressed to Patrick Campion and Andrew Gallivan, is on p. 1. The underlying request, on pp. 3 to 5, seeks executive-committee approval for Zorro Management, LLC. ⚠ No act by Gallivan is recorded anywhere in this document; he is a named recipient. The same document is cited, and was read at the image, at Jared Kushner. ⚠ Case and customer numbers appear on p. 3 and are not reproduced here. ↩

  10. 12 December 2018. EFTA01424770 p. 1, one sheet, whose whole content is the header block Subject: Accepted: Epstein discussion [I] / From: Andrew Gallivan / Date: Wed, 12 Dec 2018 11:07:28 -0500 / To: Stewart Oldfield, marked “Classification: For internal use only”, with an empty body. Read at the text layer only. A second calendar acceptance under the same subject is dated 23 October 2018, the day after the four questions. ⚠ These are calendar responses. They evidence that meetings were arranged and nothing about whether they took place or what was said. ↩

  11. Absence probes, and their scope. Four conjunctions were run over the page-level FTS index on 20 September 2026 and each returned 0 documents: Gallivan AND "grand jury", Gallivan AND deposition, Gallivan AND subpoena, Gallivan AND "consent order". ⚠ These are claims about four token conjunctions over the release’s extracted text and nothing more. The extraction of this release is known to mangle names, and two of the misreadings of his own name found for this page, “Andrew F Caravan” and “AndrewGalivan”, would defeat every one of those queries. The proper reading is that no such document was found by these searches, not that none exists. ↩

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