Epstein Data Wiki

Gwen Hill

Properties2
tagsperson, deutsche-bank, kyc, aml, compliance, pep, southern-financial, jacksonville, 2013, 2014, 2015, 2018
aliasesGwen Hill, Hill, Gwen, G Hill, G. Hill

27 min read

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

The Deutsche Bank anti-money-laundering compliance officer in Jacksonville who signed off the bank’s 2018 high-risk reviews of the Epstein entity relationships, who wrote into the bank’s own case record that the negative media on its client concerned his relationships with Bill Clinton and Prince Andrew, and who four days later put the politically exposed person question to Janice Franklin in New York and got the answer that every entity Epstein ultimately owned should be automatically rated high risk. No allegation against her was found in the release read for this page, and none is made here. ⚠⚠ A high-risk review and a rejected know-your-customer file are controls working. What this page documents is what she wrote, what she approved, and what the bank’s own forms record beside her name. ⚠⚠ NOTHING ON THIS PAGE IS A SIGNATURE. Every approval below is a printed name in a cell the form labels “(Signature)”, and the rules bear no mark. See “A printed name in a signature cell”. ⚠ No client who is a private individual is identified here beyond what the bank’s own forms name as a party to a relationship, and no case, customer, account or identity number is reproduced.

WhoGwen Hill, AVP, AML Compliance Officer, DB USA Core Corporation, Regulation, Compliance and Anti-Financial Crime, 5201 Gate Parkway, Jacksonville, per her own signature block, October 20181
Earlier titleAssociate, AML Compliance Officer, Deutsche Bank Securities Inc, PWM AML Compliance, 5022 Gate Parkway, Jacksonville, per her own signature block, October 20152
⭐⭐ The escalation, 19 Oct 2018”Please let us know if you agree that Mr. Epstein should be treated as a Relative or Close Associate (RCA) of a PEP due to his connections to Prince Andrew and Bill Clinton.”3
⭐⭐ Four days earlier, 15 Oct 2018In the bank’s own case record: “There is some negative media against Mr. Epstein and he is also maintains a close relationship with Bill Clinton and Prince Andrew.” ⚠ The grammatical slip is on the sheet4
⭐ In the same comment”Our review did not identify any red flags and thus there was no need to escalate this case further.”4
⭐⭐ And again on 26 Oct 2018The identical two passages, written four days after she closed the escalation5
⭐ Risk ratingOn the 2018 review of the Southern Financial relationship the High Risk box is ticked and her name is printed in the cell headed “(Compliance Signature)”6
⭐ 14 Mar 2014A three-item know-your-customer rejection in her own prose, including “Documentation to evidence additional signer not located.”7
⭐ 6 Oct 2015To a banker on the Mort, Inc file: “Forward the COGS and KYC number to me and I can clear the exception.”2
30 Jul 2018She retrieved a 2013 screening-alert package on Epstein from the bank’s Notes archive and routed it onward8
In the release132 documents carry her full name9
Her own messages28 sender rows across 23 documents, 6 September 2013 to 19 October 20189

The escalation: 19 October 2018

On Friday 19 October 2018 at 2:30 PM she wrote from Jacksonville to Janice Franklin, an AML compliance officer at 60 Wall Street in New York, under the subject “RE: PEP Escalation_Jeffrey E. Epstein”. The message is four short paragraphs over her own sign-off. It opens:3

Hi Janice,

The purpose of this email is to address the PEP status of Jeffery E. Epstein, an existing Wealth Management client through the Southern Financial Relationship. Although the PEP status was factored into the prior risk calculator, the client was never formally escalated as a PEP.

⚠ “Jeffery” is the spelling on the sheet and is not corrected here. She then gives her basis, and the basis is press reporting:3

It has been reported in the media that Mr. Epstein has maintained a close relationship with Prince Andrew, Duke of York and member of the British Royal Family and former US President, Bill Clinton. Several media sources have reported Mr. Clinton and Prince Andrew have used Mr. Epstein’s private passenger jet “Lolita Express” on numerous occasions.

The relationship is currently “High” Risk. Although Mr. Epstein was treated as an honorary PEP in the past, he was never formally escalated as a PEP. BLAFC-WM reached out to the business and they agreed he should remain a PEP. Please let us know if you agree that Mr. Epstein should be treated as a Relative or Close Associate (RCA) of a PEP due to his connections to Prince Andrew and Bill Clinton.

At 5:16 PM the same afternoon Franklin answered:3

Hi Gwen:

I agree with your assessment that Mr. Epstein should be treated as a RCA. Hence, all clients where he is UBO or has a significant controlling role should be automatically risk rated “High”

⚠ The double space after “PEP.” and after “RCA.” is as printed, and Franklin’s second sentence ends without a full stop. ⚠ “UBO” is the bank’s abbreviation for ultimate beneficial owner. “BLAFC-WM” is as printed and is not expanded, because nothing read for this page expands it.

On Monday 22 October 2018 at 8:53 AM she forwarded the whole exchange to the private wealth AML and KYC mailbox, copy to herself, under a subject line beginning “CLEARED:”.3 ⚠ That word records that the escalation was closed. It does not record what the bank then did, and nothing read for this page shows the automatic high rating Franklin described being applied to any particular account. Jeffrey Epstein was arrested eight and a half months later, on 6 July 2019.

⚠⚠ Did she make the assessment, or pass it on? The case record answers it, and the answer is four days early

Franklin’s reply says “your assessment”, which presupposes an assessment. Her escalation is itself a reply, its subject line carrying “RE:”, so an earlier message in that thread existed. No message with that subject and no “RE:” prefix is in the release, and neither copy of the exchange carries anything below her 2:30 PM message.310 On the face of the correspondence alone the question would not be settleable.

It is settleable from the bank’s own case record, which nobody had opened. On Monday 15 October 2018 at 3:03 PM, four days before the escalation, she entered a comment into the case file for the high-risk review of JEGE Inc, JEGE LLC and Jeepers Inc. Under the heading Created By: Gwen Hill, it reads in full:4

This KYC serves as a high risk review for JEGE Inc, JEGE LLC and Jeepers Inc (herein referred to as “accountholders”) – Below are the reasons why we are comfortable with approving this KYC: • Information and supporting documents required by our AML Policy were provided and reviewed; and as a result, we have an understanding of the structure of the accountholders, their purpose, the purpose of the accounts and expected transaction activity. • There are a few risk factors associated with the accountholders – -SOW: The UBO (Jeffrey Epstein) is the founder of Southern Trust Company Inc, which manages client’s assets. SOW verification was obtained. -Negative Media & PEP: There is some negative media against Mr. Epstein and he is also maintains a close relationship with Bill Clinton and Prince Andrew. Please see risk calculator for more information. Appropriate approval was obtained. • Our review did not identify any red flags and thus there was no need to escalate this case further. • We performed due diligence searches on all parties and did not find the names searched to be on any sanctions lists.

⚠ “he is also maintains” is on the sheet at 500 dpi and is not corrected here. ⚠ “SOW” is the bank’s abbreviation for source of wealth, and the company her comment names as managing the client’s assets is Southern Trust Company.

So the two names, and the media basis, are in her own written hand in the bank’s case system four days before she put the question to New York. Documented fact: the substance of the assessment Franklin agreed with was recorded by her, under her name, on 15 October. ⚠ What the sheets do not settle is whether she first formed it or first received it, because the passage is standard-form language she also used on other files, and because the message that made her escalation a reply is absent. The page claims the authorship of the written record and no more.

⚠⚠ The sentence she wrote again on 26 October, and the question it raises

On Friday 26 October 2018 at 4:06 PM she entered a comment into a second case file, for the high-risk review of LSJE LLC and Southern Financial LLC. ⚠ It is the same paragraph structure, the same “Negative Media & PEP” passage naming Bill Clinton and Prince Andrew, and the same closing bullets, including:5

• Our review did not identify any red flags and thus there was no need to escalate this case further.

She wrote that seven days after escalating the politically exposed person question in writing, and four days after closing it herself with “CLEARED:”.

⚠⚠ This page does not call that a contradiction, and here is why the restraint is required. The forms do not define what “escalate this case further” means, and an AML function may reserve the word for a referral above the level the escalation reached. Both comments also say “Appropriate approval was obtained” about the same risk factor, and on 15 October that phrase cannot refer to Franklin’s determination, which did not yet exist. Nothing read for this page says what approval either sentence means. The question the sequence puts, and it is a question: if the politically exposed person status of the bank’s client was live enough to escalate on 19 October, on what basis did the case record for a second Epstein relationship state on 26 October that there had been no need to escalate? Nothing read for this page answers it.

⚠ A printed name in a signature cell

Every approval on these forms is a printed name, and the rules bear no mark. On the 15 October review the AML Compliance row carries the heading “(Signature)” and beneath it two names, Sandra Timpone and Gwen Hill, each against 10/15/2018; the client-facing and business-head rows are laid out the same way for Stewart Oldfield and Andrew F Gallivan against 9/28/2018.4 On the 26 October review the same cell carries Richard Cottrell and Gwen Hill against 10/26/2018, with Oldfield and Gallivan against 10/15/2018.5 On the Part B sheet of the 2018 Southern Financial review the “High Risk” box is ticked and her name is printed in the cell headed “(Compliance Signature)”.6

⚠⚠ All four were read at the image and in no case is there a mark on the rule. What the forms record is that an approval was entered under her name in the bank’s system, which is not the same fact as her having signed anything, and this page does not write that she signed.

⚠ On the same Part B sheet the bank’s own summary of its negative database results appears at section D. It records against the client’s name that the negative media, the court cases and the criminal filings all relate to “the sex offence in the past”, each “already cleared”, and that an alert had been “found” and cleared with the clearance attached.6 ⚠⚠ THE SHEET DOES NOT NAME THE AUTHOR OF SECTION D, and this page does not attribute it to her. Her name appears on that sheet only in the compliance-signature cell against the risk rating.

2013 to 2015: what is hers inside an automated notice

The largest block of her traffic carries a subject line a machine wrote. “Your KYC has been approved!” and “Your KYC has been rejected” are template subjects, and the bodies under them open with template sentences. The test applied on the sibling files at this bank is whether the free-text field is the human’s, and on her one rejection it plainly is.

On 14 March 2014 at 2:46 PM a rejection went to Amanda Kirby on the Jeepers, Inc file under the relationship name “EPSTEIN, JEFFREY RELATIONSHIP”. The system wrote the headline and the case lines. The reason field is three numbered items in ordinary English:7

Reason for Rejection:1. Documentation to evidence additional signer not located.

  1. Signers per KYC do not agree to Certificate of Corporate Resolution.

  2. KYC has Jeanne Brennen listed as a signer. Jeanne is not listed on the Corporate Resolution. Will Jeanne still sign on the account? If not, please remove. If so, please update Corporate Resolution.

⚠ What she caught is a mismatch between two of the bank’s own documents: the signers named on the know-your-customer file did not match the company’s certificate of corporate resolution. Twelve days later, on 26 March 2014, the same file was approved by a notice under her name carrying no free text at all.11 ⚠ Nothing read for this page shows what was supplied in between.

⚠⚠ The rest of her notice traffic carries no authored text whatever. The approvals of 6 September 2013, 26 March 2014 and 5 October 2015 are the system envelope and nothing else, and a name on a system-generated notice is not an act. The counts below should be read with that in mind.

October 2015: the Mort, Inc exception

On Monday 5 October 2015 at 3:18 PM an approval notice went out under her name on the Mort, Inc file to JJ Litchford, an associate banker at Deutsche Bank Trust Company Americas. ⚠ A minute later, at 3:19 PM, she answered in her own words: two of them, misspelled. That is the distinction this page turns on. The notice is a system envelope; the reply is a person.12 The approval had been granted on a temporary exception. At 4:53 PM Litchford asked “I have received the new certificate of good standing, how can I get the temporary exception cleared?” Her answer the next morning at 9:01 AM is one sentence:2

Forward the COGS and KYC number to me and I can clear the exception.

Litchford sent both back at 9:37 AM with the certificate attached,2 and at 9:50 AM she recorded that the exception was closed.13 ⚠ That closing message was read at the text layer only and not at an image, and it is the only copy of it found in the release.13

⚠ Mort, Inc is one of the accounts Kimberly Hart ordered closed on 8 July 2019, two days after Epstein’s arrest.

30 July 2018: the alerts out of the archive

On Monday 30 July 2018 at 3:53 PM, writing on behalf of the private wealth AML and KYC mailbox, she forwarded a message out of the bank’s Notes archive to Carl Timcke.8 What she forwarded is a screening package dated 29 May 2013 from the bank’s research function, addressed to a colleague, whose body reads “Attached is an alert for the party mentioned above. Please note that clearance from compliance is required prior to KYC approval.” and which carries five attachments named as two RDC alerts and three PCR alerts on Jeffrey Epstein.8

⚠⚠ She wrote nothing. The act is the retrieval and the routing, not any words of hers, and it is recorded here because of where it sits: seventy-seven days before the first of the 2018 high-risk reviews and eighty-one before the escalation, a 2013 alert package on the bank’s client was pulled out of an archive and sent on.

Who she was at the bank

Her own signature blocks record a change of grade, of legal entity and of office between 2015 and 2018. In October 2015 she signed as Associate, AML Compliance Officer, Deutsche Bank Securities Inc, a Member of Deutsche Bank Group, PWM AML Compliance, at 5022 Gate Parkway, Suite 400, Jacksonville.2 In October 2018 she signed as AVP, AML Compliance Officer, DB USA Core Corporation, Regulation, Compliance and Anti-Financial Crime, at 5201 Gate Parkway, 2nd Floor, Jacksonville.1

⚠ Both blocks were read at the image, and both are described rather than quoted as a single string, because a signature block extracts as separate runs and a quoted line from one is not a line anybody wrote. ⚠ No contact value from either block is reproduced here.

Janice Franklin, the officer she escalated to, signed from Deutsche Bank Americas at 60 Wall Street in New York. ⚠ They are different legal entities within the same group and the escalation crossed between them, which is what an escalation to “AML Compliance” in the New York signature chain appears to have meant on this relationship.

⚠ What this page does not establish

  • Whether she originated the politically exposed person assessment or received it. The written record under her name predates the escalation by four days; the message that made her escalation a reply is absent from the release.10
  • What “escalate this case further” meant on these forms, and therefore whether the 26 October comment is inconsistent with her own escalation seven days earlier.
  • What the bank did after 22 October 2018. Nothing read for this page records the automatic high rating being applied to any account.
  • Whether she signed anything. Every approval read here is a printed name in a cell headed “(Signature)”, with no mark on the rule.
  • Who wrote section D of the Part B sheet. The form does not say.
  • Anything about her after 22 October 2018. Her latest message in the release is the escalation itself; the “CLEARED:” forward of 22 October is the last document read here that carries her name as sender.

Timeline

DateWhat the document recordsArranged / occurredSource
6 Sep 2013Approval notice under her name on the Jeepers, Inc file to Amanda Kirby. System envelope, no authored textoccurred11
14 Mar 2014Rejection notice on the same file, with her three-item reason field naming a signer mismatchoccurred7
26 Mar 2014Approval notice on the same file. System envelope, no authored textoccurred11
11 Feb 2015Her name printed in the AML Compliance approval cell of a KYC form, beside Yoonsun Chung ⚠ text layer onlycannot-tell14
5 to 6 Oct 2015The Mort, Inc temporary exception: her instruction, then her record that it was cleared ⚠ the close is text layer onlyoccurred213
30 Jul 2018She forwards a 2013 RDC and PCR alert package on Epstein out of the Notes archiveoccurred8
15 Oct 2018, 3:03 PMHer case comment approving the high-risk review of JEGE Inc, JEGE LLC and Jeepers Inc, naming Clinton and Prince Andrew and stating no need to escalateoccurred4
19 Oct 2018, 2:30 PMHer written PEP escalation to Janice Franklinoccurred3
19 Oct 2018, 5:16 PMFranklin agrees: treat Epstein as an RCA; all clients where he is UBO automatically rated Highoccurred3
22 Oct 2018, 8:53 AMShe forwards the exchange to the AML and KYC mailbox under “CLEARED:“occurred3
26 Oct 2018, 4:06 PMHer case comment approving the high-risk review of LSJE LLC and Southern Financial LLC, repeating that there was no need to escalateoccurred5
6 Jul 2019Jeffrey Epstein arrestedoccurred15
8 Jul 2019Mort, Inc is among the accounts ordered closedoccurred15

⚠ A note on the dates printed in the case record

The case-comment rows on these printouts render the year as three digits. The two comments above are dated on their own sheets 10/15/118 3:03 PM and 10/26/118 4:06 PM, and the neighbouring rows by other staff read 9/20/118 and 8/24/118. This is on the sheets, at 500 dpi, in both documents, and it is not an extraction fault.45 The approval blocks on the same sheets print four-digit years correctly. This page reads 118 as 2018, on the strength of the four-digit dates in the approval blocks immediately below and of the correspondence, and says so rather than silently mending it.

Footnotes

  1. 19 and 22 October 2018. EFTA01299337 p. 2, a two-sheet document, read at the image at 700 dpi. Her signature block, described rather than quoted, reads across five lines beneath a script rendering of her name: Gwen Hill / AVP | AML Compliance Officer / DB USA Core Corporation / Regulation, Compliance and Anti-Financial Crime / Anti-Financial Crime / 5201 Gate Parkway, 2nd Floor, 32256 Jacksonville, USA. A bar covers the block beneath the address and nothing under it is reproduced or described. ⚠ The text layer of this sheet is unreliable: it renders her script sign-off as Gwent, Hal. and drops most of the address line. The sheets carry CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e). ↩ ↩2

  2. 6 October 2015, the instruction, and her 2015 signature block. EFTA01359789 p. 1, read at the image at 600 dpi. A single sheet carrying three messages: Litchford at Monday, October 05, 2015 4:53 PM asking how to clear the temporary exception; her reply at Tuesday, October 06, 2015 9:01 AM reading Forward the COGS and KYC number to me and I can clear the exception.; and Litchford’s 10/6/2015 9:37:10 AM reply attaching Mort Inc_Certificate of Good Standing_100515..pdf. Her 2015 signature block is on the same sheet, described in the body above; no contact value from it is reproduced here. A KYC case number printed in Litchford’s message is not reproduced. ⚠ This footnote pins ONE sheet and every string quoted from it is on that sheet. The same sentence also stands on EFTA01403015 p. 1, EFTA01403210 p. 1 and EFTA01359254 p. 1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  3. The escalation and its close. EFTA01299337 p. 1 and p. 2, both read at the image at 700 dpi. ⚠ The run is a container and page 1 is a wrapper: the topmost header on p. 1 is her own forward to the private wealth AML and KYC mailbox, copy to herself, subject CLEARED: PEP Escalation_Jeffrey E. Epstein, dated Monday, October 22, 2018 8:53:18 AM, one attachment. Beneath it on the same sheet is Franklin’s message of Friday, October 19, 2018 5:16 PM, and beneath that the opening of Hill’s message of Friday, October 19, 2018 2:30 PM, which continues onto p. 2 and ends there with her sign-off. The quotations above are given in the order the correspondence happened, not the order it prints. A second copy of the same chain, one stage earlier, is EFTA01299334 p. 1 and p. 2, read at the image at 400 dpi; its top message is Franklin’s reply timed Friday, October 19, 2018 5:15:52 PM, so the two copies give that message to the second and to the minute respectively. ⚠ No contact value from any header or signature line on either copy is reproduced here. ⚠ Why a checker may flag the Franklin quotation: her second sentence ends risk rated "High" with a closing curly quotation mark and no full stop. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  4. 15 October 2018, the case comment. EFTA01298687 p. 18, read at the image at 500 dpi. ⚠ The run is a 19-sheet KYC Print of a Deutsche Bank private wealth know-your-customer form for the SOUTHERN FINANCIAL RELATIONSHIP, relationship manager Stewart Oldfield, marked on its page 1 as a 2018 Periodic Review - HR Overdue KYC. Cite the page, not the bare identifier. The sheet’s own footer Bates is EFTA_00174139. The comment is quoted whole above; the row is headed Created By: Gwen Hill, dated 10/15/118 3:03 PM. A second row on the same sheet, Alka Babu, 8/24/118 5:52 AM, reads No material changes confirmation "email" attached in the case. ⚠⚠ The text layer of this sheet invents two personal names: it renders Alka Babu as Alla Gatti and Stewart Oldfield as Stewart Oilfield and otewart Oldfield. The image governs. ⚠⚠ Why a checker will not bind the “Negative Media & PEP” sentence to this sheet, and why the pin is right: the text layer of EFTA01298687 p. 18 renders it -Negative Media & PEP: There Is some negative media against Mr. Epstein and he Is also maintains a close relationship with 84II Clinton and Prince Andrew. — Is twice for is, and 84II Clinton for Bill Clinton. The sheet reads as quoted above, at 500 dpi. The ONSHORE APPROVALS block below carries Stewart Oldfield and Andrew F Gallivan against 9/28/2018 and, in the AML Compliance row, Sandra Timpone and Gwen Hill against 10/15/2018; the cell is headed (Signature) and carries no mark. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  5. 26 October 2018, the second case comment. EFTA01282225 p. 20, read at the image at 500 dpi. ⚠ A 21-sheet KYC Print of the same form for the same relationship; page 1 records the last approved files as LSJE LLC and Southern Financial LLC. Cite the page, not the bare identifier. The sheet’s own footer Bates is EFTA_00148244. Her row is headed Created By: Gwen Hill, dated 10/26/118 4:06 PM, and the text is the passage quoted above; the preceding row is Mayur Rathod, 9/20/118 7:46 AM. ⚠ The text layer renders Mayur Rathod as mayor Rathod and, in a sibling copy, as Mayur Rattled, and renders Prince Andrew as Prime Andrew; the image reads Prince Andrew. The AML Compliance row carries Richard Cottrell and Gwen Hill against 10/26/2018, printed in a cell headed (Signature) with no mark, over Stewart Oldfield and Andrew F Gallivan against 10/15/2018. ⚠ At least two further copies of this comment sit in the release; they are not relied on here and nothing is inferred from the difference between copies. ⚠⚠ A phrase search cannot count them: one copy’s text layer renders high risk review as high rlsk review and another as high nsk review, so the copies are reachable only by reading, and two is a floor and not a total. ↩ ↩2 ↩3 ↩4 ↩5

  6. The risk rating and the database results. EFTA01298687 p. 16, read at the image at 600 dpi. DB PWM GLOBAL KYC/NCA: US/LatAm/Int'l PART B, relationship name SOUTHERN FINANCIAL RELATIONSHIP. The High Risk box is ticked and Gwen Hill is printed in the adjoining cell, above a caption reading (Compliance Signature). There is no mark. Section D, Please summarize any negative results from the database searches indicated above, carries entries for several named parties; against Jeffrey Edward Epstein it reads, in part, Negative media relates to the sex offence in the past which are already cleared, Criminal Filings relates to sex offence which is already cleared in the past and RDC alert found - Sex offences in the past which has been cleared - Clearance attached. ⚠⚠ The sheet does not name the author of section D and this page does not attribute it. ⚠ Identity numbers printed beside two names on this sheet are not reproduced. ↩ ↩2 ↩3

  7. 14 March 2014, the rejection. EFTA01357873 p. 1, read at the image at 600 dpi. A single sheet. Subject Your KYC has been rejected, from Gwen Hill to Amanda Kirby, 3/14/2014 2:46:05 PM, relationship EPSTEIN, JEFFREY RELATIONSHIP, customer Jeepers, Inc. No case or customer number is reproduced here. ⚠⚠ The text layer of this sheet lowercases four words the sheet capitalises (signers, certificate of corporate Resolution, will, if), which matters because the sibling page at this bank treats typing slips in a reason field as evidence of human authorship. At the image there are no such slips in this one; the evidence of authorship here is that the field is three numbered items of ordinary English naming a specific documentary mismatch, not that it is badly typed. ↩ ↩2 ↩3

  8. 30 July 2018, the archive forward. EFTA01371882 p. 1, read at the image at 500 dpi. A single sheet. Header: From: Gwen Hill on behalf of PWMUS AMLKYC, Sent: Monday, July 30, 2018 3:53 PM, To: Carl Timcke, subject Fw from Notes archive: Fw: Jeffrey Epstein __RDC Alert,Jeffrey Epstein__PCR Alert [I], with five named attachments. Beneath a rule reading -----Forwarded by Gwen Hill/db/dbcom on 07/30/2018 03:52PM ----- sits the enclosed message: From: PWM BIS-Research/db/dbcom, Sent by: Ashish-s Sain/db/dbcom, Date: 05/29/2013 11:43AM, classification For internal use only, opening Hi Amanda, and reading Attached is an alert for the party mentioned above. Please note that clearance from compliance is required prior to KYC approval. followed by three numbered instructions. The To: line of the enclosed message is barred. She added no text of her own. ↩ ↩2 ↩3 ↩4

  9. Counts, with both denominators, measured 20 September 2026. 132 documents in the release carry the phrase "Gwen Hill", across 168 pages. Her sender rows number 28, across 23 distinct documents, dated 6 September 2013 to 19 October 2018. The release as queried holds 1,425,606 documents, of which 1,117,562 carry at least one parsed sender row; so her 23 documents are 23 of 1,425,606 against the whole, and 23 of 1,117,562 against documents with any sender. ⚠⚠ Twenty-five of the 28 sender rows are the automated approval or rejection envelope, so the raw sender count overstates the authored record by roughly an order of magnitude. ⚠ "Gwendolyn Hill" returns 0 documents and "Gwendolyn" alone returns 54, none of them shown to be her. ⚠ The bare surname is not a usable key: three unrelated people named Hill appear elsewhere on this wiki, and the bare token "Gwen" returns 382 documents against her full name’s 132. ⚠ Scope: these are counts of the full-text index and of the parsed e-mail metadata, not of every sheet in the release. ↩ ↩2

  10. The absent first message. Both copies of the chain end at her 2:30 PM message; nothing sits below it on either.3 A query of the release’s e-mail index for the subject PEP Escalation_Jeffrey E. Epstein returns five rows across the two documents above, every one of them carrying the RE: or CLEARED: prefix, and none is the message that started the thread. ⚠ Scope: that is a search of sender and subject rows, not of the whole corpus, and it is stated as a search result rather than as an absence. ↩ ↩2

  11. The approval notices, and what is not in them. EFTA01360636 p. 1, 9/6/2013 4:49:24 PM, to Amanda Kirby, customer Jeepers, Inc; EFTA01358191 p. 1, 3/26/2014 2:30:00 PM, to Amanda Kirby, customer Jeepers, Inc; EFTA01359909 p. 1, 10/5/2015 3:18:29 PM, customer Mort, Inc. ⚠ All three read at the text layer only. Each is the same template throughout: the headline The KYC you had submitted has been approved., a link line, three case and customer lines, and a closing instruction to forward the message as proof of approval. There is no free-text field and no authored sentence in any of them. Case and customer numbers are not reproduced. ↩ ↩2 ↩3

  12. 5 October 2015. Her one-word reply of Mon, 05 Oct 2015 15:19:44 -0400, Your welcome, at EFTA01359646 p. 1. ⚠ Text layer only. The misspelling is as printed. ↩

  13. 6 October 2015, the close. Her message of Tue, 06 Oct 2015 09:50:04 -0400, reading The cert of good standing has been added to the KYC and the exception is cleared., at EFTA01403210 p. 1. ⚠⚠ READ AT THE TEXT LAYER ONLY AND NOT AT AN IMAGE, and it is the only copy of that message found in the release. ↩ ↩2 ↩3

  14. 11 February 2015, the earlier approval block. EFTA01372870 p. 1, READ AT THE TEXT LAYER ONLY AND NOT AT AN IMAGE. The ONSHORE APPROVALS block records Paul Morris and Kimberly Hart against 2/10/2015 and, in the AML Compliance row, Yoonsun Chung and Gwen Hill against 2/11/2015. ⚠⚠ Because it has not been read at an image, this page does not state whether the cell bears a mark, and the row is marked cannot-tell in the timeline for that reason. ⚠ The text layer renders her name in the second column as Gwen HA. ↩

  15. The arrest and the closures. The 6 July 2019 arrest and the 8 July 2019 closure instruction, including Mort, Inc among the accounts listed, are documented at Kimberly Hart and are not re-derived here. ↩ ↩2

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