⚠ what this page is about, and what it is not
The Deutsche Bank officer who took the question of whether Epstein could open another account up the bank’s own reputational-risk chain, and got back an instruction to commission a Kroll investigation of him. No allegation against him was found anywhere in the release, and none is made here. ⚠ Escalating a client to a risk committee is the control working, not failing.
| Who | Daniel Sabba, at Deutsche Bank1 |
| In the release | 3,419 documents2 |
| His own messages | 1,831 sender rows across 1,260 documents, to January 20172 |
| ⭐ The act | On 20 January 2016 he asked whether a new account for Epstein’s charity could be opened on existing approvals “or whether this has to be brought to the RRC”, the bank’s Reputational Risk Committee3 |
| ⚠ The answer, next morning | ”The committee wants an updated due diligence report.” The reply goes on to ask for a named corporate-investigations firm’s background report on Epstein, quoted in full below3 |
| And | 165 of his messages carry the subject “Epstein account opening”2 |
Daniel Sabba appears in the release as one of the Deutsche Bank people through whom the Epstein relationship was administered. His distinctive contribution is that he escalated.
January 2016: the Reputational Risk Committee
On 20 January 2016 he wrote to a colleague in the bank’s risk function, copying three others:
Hi Carol — Wayne Salit suggested we reach out to you. Jeffrey Epstein has requested the opening of a new DBSI account for one of his entities (Gratitude America, Ltd.). We have reached out to Wayne to clarify whether this can be done with the approvals we have in place or whether this has to be brought to the RRC. Wayne deferred the question to you - the email below has the specific guidance received from Jan Ford. Can you please advise if possible.
At 09:30 the next morning the answer came back, under “Classification: For internal use only”:
The committee wants an updated due diligence report. Can you order a level 2 kroll report? (I think it is level 2). Thx
⚠⚠ WHAT THIS DOCUMENTS. In January 2016 Epstein asked Deutsche Bank to open an account for Gratitude America, Ltd., his charitable entity. The request was not handled routinely: it went to the bank’s reputational-risk function, and the committee’s response was to require fresh due diligence and a commissioned background investigation by the corporate investigations firm named in the message.
⚠ This is the control operating. A page about a bank’s failures should record its controls working as readily as it records them failing, and the page says so. ⚠⚠ What is NOT established by any document read here: what the Kroll report said, whether it was produced, whether the committee approved, or whether the account was opened.3
⚠ Two months later the relationship was still live, and by the following year the bank’s own know-your-customer file for the wider relationship recorded “Our review did not identify any red flags”. That document is treated at Southern Financial, LLC and this page draws no line between the two, because none is drawn in anything read for it.
The account-opening traffic
165 of his messages carry the subject “Epstein account opening”, alongside Paul Morris’s parallel thread of March 2013. ⚠ The desk did not open them for this draft and states that rather than characterising them.2
What the 3,419 documents are
⚠ No doc_type split is quoted. The desk measured that classifier at 100% on email.header
but 5% on court.plea_agreement and 52% on financial.equity_swap, and the rule in
_desk/TOOLS.md is that any other label must be spot-checked before it is printed.2
What this page does not say
No allegation against him was found anywhere in the release.4
⚠⚠ NOTHING HERE SUGGESTS HE DID ANYTHING IMPROPER, AND THE DOCUMENT SHOWS THE OPPOSITE SHAPE: a banker asking whether a thing needs committee approval, rather than assuming it does not. ⚠ Whether Deutsche Bank’s controls were adequate overall is an institutional question and belongs at Deutsche Bank, not to any individual named here.
Related
Footnotes
Footnotes
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Identification. ⚠ No document read for this page states his title or division. He is described here as “at Deutsche Bank” on the strength of the internal distribution he writes into and the bank classification markings on his messages. ⚠ A sister page was corrected this week for taking a job title from a colleague’s signature block, and this page takes none. ↩
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The measurement.
"Daniel Sabba"returns 3,419 documents. ⚠ The hinge is page scope: a document counts when any one of its pages carries the phrase. In the e-mail metadata store he is the sender of 1,831 rows across 1,260 documents, the latest dated 31 January 2017. 165 of those rows carry the subjectEpstein account opening(126 asRE:, 39 as the bare subject), and 42 carryFW: Jeffrey Epstein/Southern Financial LLC - Rep Risk Appr…. ⚠ The desk opened one document of the reputational-risk thread and none of the account-opening thread, and says so rather than characterising them. ⚠ Nodoc_typefigure is printed, under the rule recorded in_desk/TOOLS.md. ⚠ No deduplicated message total is stated. ↩ ↩2 ↩3 ↩4 ↩5 -
20 and 21 January 2016. EFTA01479324 p.1, read at the image at 700 dpi, subject
RE: Jeffrey Epstein/Southern Financial LLC - Rep Risk Approval [C] [I]. Sabba’s message is timedWednesday, January 20, 2016 2:57 PM; the reply is headedThu, 21 Jan 2016 09:30:44 -0500underClassification: For internal use only; an earlier message in the chain is datedTuesday, January 19, 2016 2:10 PM. The double spaces in the reply are as printed. ⚠ “RRC” is expanded here as the Reputational Risk Committee on the strength of the subject line’s “Rep Risk Approval”; the sheet does not expand it. ⚠ “DBSI” is not expanded, because the sheet does not. ⚠ Four further Deutsche Bank people are named on the sheet and are not named here, because nothing on this page turns on them; no e-mail address from this sheet is reproduced. ⚠⚠ No document read for this page records what the Kroll report said, whether it was produced, whether the committee approved the account, or whether it was opened. Copies of the same thread exist at EFTA01461120, EFTA01479304, EFTA01399039 and EFTA01479319; none was separately rendered. ↩ ↩2 ↩3 -
Absences, each scoped. No allegation against him was found in the release read for this page. ⚠⚠ This is a narrow check against 3,419 documents and is stated as one: the desk opened one thread. It ran no systematic adverse sweep, searched none of the six derived stores, and did not open the 165 account-opening messages. ⚠ A deeper pass is owed, and this page records the debt rather than implying it does not exist. ↩