⚠ what this page is about, and what it is not
The Deutsche Bank assistant vice president who in October 2018 asked the bank’s control officer to approve carrying on with the Epstein know-your-customer remediation, and who supplied a court notice of dismissal as the answer to the lawsuit that had just surfaced against the client. No allegation against him was found anywhere in the release, and none is made here. ⚠ On the sheets read for this page he is relaying a requirement compliance had set and forwarding a court document. Nothing read here shows him withholding anything from anybody.
| Who | Richard Iarossi, Assistant Vice President, Deutsche Bank Wealth Management, 345 Park Avenue, 24th Floor, New York, per his own signature block1 |
| In the release | 292 documents2 |
| His own messages | 115 sender rows across 85 documents, 3 July 2015 to 29 November 20182 |
| ⭐ The act, 18 Oct 2018 | ”AML Compliance (Yoonsun) has requested that we receive your approval to move forward on all Southern Financial/Epstein KYC remediation’s.”3 |
| ⭐ and, in the same message | ”As per your discussions with Stew regarding the latest lawsuit against Jeffrey, please find the attached ‘Notice of Dismissal’ dated 10/5/18.”3 |
| ⚠ The follow-up, 22 Oct 1:36 PM | ”Compliance has asked that we obtain your approval to continue the KYC approval process.”3 |
| ⭐⭐ 5 Oct 2018, 2:07 PM | ”Please see the attached form to increase the daily wire limit to $20mn for Jeffrey Epstein.”4 |
| Classification | ”For internal use only” on every sheet of both threads34 |
18 October 2018: what he was asking the control officer to approve
Nine days after a link to a filed Ponzi-scheme complaint surfaced in Deutsche Bank’s own know-your-customer review, Iarossi wrote to the bank’s Divisional Control Officer. That the suit was brought against the bank’s client is established on the sheets by the control officer’s own reply, which asks why it was brought against Mr. Epstein. He is not a named party on either of the two 9 October messages that opened that matter; he enters the chain here, as its sender.3
AML Compliance (Yoonsun) has requested that we receive your approval to move forward on all Southern Financial/Epstein KYC remediation’s.
As per your discussions with Stew regarding the latest lawsuit against Jeffrey, please find the attached ‘Notice of Dismissal’ dated 10/5/18.
As this occurred after your approval on 10/2/17, please confirm again that we are comfortable moving forward.
⚠⚠ THREE THINGS THIS MESSAGE IS, AND ONE IT IS NOT. It is a request for a control officer’s approval, made because AML Compliance had asked for one. It supplies a document titled ‘Notice of Dismissal’, dated 5 October 2018, as the answer to the adverse item. It names a prior approval of 2 October 2017 and asks for that approval to be given again in the light of what had happened since. ⚠ It is not a decision, and nothing in it decides anything: the officer it is addressed to holds the approval, and the sequence at Kimberly Hart and Stewart Oldfield sets out what she asked in reply.3
⚠ The two dates in the message are written in the sheet’s own numeric form, and are read here as US month-first: 10/5/18 as 5 October 2018 and 10/2/17 as 2 October 2017. ⚠ “Yoonsun” is a first name only on this sheet and no surname is supplied here from any other document. ⚠ “Stew” is the message’s own familiar form for the relationship director. ⚠⚠ The ‘Notice of Dismissal’ is an attachment and is NOT in this document. It was not read, and nothing on this page describes what it says, which court it is from, or what it dismissed.3
22 October: the follow-up, and the four questions it drew
Four days later, at 1:36 PM on Monday 22 October, he wrote again, to the same officer, copying the same two colleagues:
I hope you had a nice weekend.
Just wanted to follow up on the below. Attached is the Dismissal Notice for the latest lawsuit filed against Jeffrey Epstein. Compliance has asked that we obtain your approval to continue the KYC approval process.
Please let me know if you have any questions or would like to discuss.
Fifty-four minutes later the control officer answered him. Her reply is addressed to Iarossi by name, copies three colleagues including Andrew Gallivan, and puts four numbered questions about the client’s connection to the matter behind the complaint. The four questions are given in full at Stewart Oldfield and are not restated here; the point for this page is that they were put to him, and that nothing read for this page records him answering them. The chain runs on to 1 November without him: on the sheets where a recipient list prints, he is not named on any message after 22 October.3
5 October 2018: the daily wire limit
A second, separate thread of the same month shows the other half of his job. On Friday 5 October 2018 at 2:07 PM he wrote to two colleagues in the bank’s product function, copying the relationship director and a wealth-management vice president:
Hi Tony/ Arthur,
Please see the attached form to increase the daily wire limit to $20mn for Jeffrey Epstein. Please let me know if anything else is needed for your approval.
Fourteen minutes later one of them set out the sign-off sequence:
First we need the primary officer for the relationship to sign on the form to authorize. Then Tony or I can approve for product team along with a business lead (Andrew Gallivan).
On Tuesday 9 October at 4:42 PM Iarossi returned the form: “Please see the attached form now signed by Stew. Please let me know if anything else is needed on my end.” The next morning, at 09:56:15 with an explicit offset of minus four hours, the reply came: “I approve of the wire limit for Product. You also need a business lead (e.g., Andrew Gallivan) to approve.”4
⚠⚠ WHAT THIS DOCUMENTS AND WHAT IT DOES NOT. It documents a request to raise one client’s daily wire limit to twenty million dollars, and an approval chain of at least three signatures running from the relationship’s primary officer through the product team to a named business lead. ⚠ It does not document that the limit was raised: no document read for this page records the business lead’s approval, the executed form, or any wire sent under a raised limit. ⚠ The form itself is an attachment and is not in this document. ⚠ Neither figure on the sheet is an account identifier and none is reproduced here.4
The two threads, side by side
Both threads run through the same three weeks and the same handful of people, and neither refers to the other in anything read for this page. The dates below are the dates and clock times the sheets themselves print.
| When | What the sheet records | Where |
|---|---|---|
| 5 Oct 2018, 2:07 PM | Iarossi sends the form to raise the daily wire limit to $20mn | EFTA01423553 p.2 |
| 5 Oct 2018, 2:21 PM | The reply: the relationship’s primary officer must sign the form first | EFTA01423553 p.1 |
| 5 Oct 2018 | The date borne by the ‘Notice of Dismissal’ he later attaches | EFTA01423573 p.5 |
| 9 Oct 2018, 11:03 AM | The relationship director tells the control officer the complaint has surfaced. Iarossi is not a party | EFTA01423573 p.7 |
| 9 Oct 2018, 12:15 PM | The control officer asks where the hit came from. Iarossi is not a party | EFTA01423573 p.6 |
| 9 Oct 2018, 4:42 PM | Iarossi returns the wire-limit form, signed | EFTA01423553 p.1 |
| 10 Oct 2018, 09:56:15 -0400 | Product approves the wire limit; a business lead must also approve | EFTA01423553 p.1 |
| 18 Oct 2018, 5:22 PM | Iarossi asks the control officer to approve continuing the remediation | EFTA01423573 p.5 |
| 22 Oct 2018, 1:36 PM | Iarossi follows up | EFTA01423573 p.4 |
| 22 Oct 2018, 2:30 PM | The control officer’s four questions, addressed to Iarossi | EFTA01423573 p.3 |
⚠⚠ READ THIS TABLE AS A SEQUENCE, NOT AS A CAUSE. The question it raises, and does not answer, is whether the product team that approved a twenty-million-dollar daily wire limit on 10 October knew of the item that had surfaced in the KYC review the day before. No document read for this page answers it, and the relationship director is the only person copied on both threads. ⚠ Nothing read here shows Iarossi knowing of the media item before 18 October, when he writes about it himself; he is not a named party on either 9 October message.
What the rest of the traffic is
His own sender rows run 2015, 2016 and 2018 and stop. By year: 4 rows in 2015, 23 in 2016, 85 in 2018, with three rows carrying no date in the metadata store and no row at all in 2017. ⚠ That is an absence of dated rows in one derived store, not an absence of acts, and this page does not treat it as one.2
24 of his 115 sender rows carry the negative-media subject line in one of its three forms. Other recurring subjects are “Monthly Annual Client Update Reports” (24 rows across three forms), “wiring limit” and “Wiring limit increase” (12 rows across eight forms, several of them damaged in the store), “Butterfly Trust - new brokerage account needed” (8), “Prime Overseas Investments and Enterprises Limited - Annual” (8), “Any chance you also have the Mort certificate handy?” (5) and “2 bank accounts closing” (3). ⚠ These are subject strings from a derived metadata store, not documents. The desk opened two documents for this page, and does not characterise the others.2
What this page does not say
No allegation against him was found anywhere in the release read for this page.5
⚠⚠ NOTHING HERE SUGGESTS HE DID ANYTHING IMPROPER. In both documents read he is an assistant vice president moving a file through his own bank’s approval machinery: asking a control officer for the approval compliance had told him to obtain, attaching the court document that bore on the question, and routing a wire-limit form to the people whose signatures it needed. ⚠ Whether Deutsche Bank should have had this client at all, and whether its review of him was adequate, are institutional questions that belong at Deutsche Bank, not to any individual named here.
⚠ He is named in none of the three public instruments this wiki cites most often for this relationship: not in the Department of Financial Services consent order of July 2020, not in the first amended class-action complaint against the bank, and not in the bank’s September 2019 presentation to federal prosecutors.5
Related
- Deutsche Bank
- Kimberly Hart
- Stewart Oldfield
- Southern Financial, LLC
- Amanda Kirby
- Vahe Stepanian
- Daniel Sabba
Footnotes
Footnotes
-
Identification. Title and employer are taken from his own signature block as it prints on every sheet he sent that was read for this page: the block gives his name, then
Assistant Vice President, thenDeutsche Bank Wealth Management, then345 Park Avenue, 24th Floor, thenNew York, NY 10154. Read at the image at 700 dpi on EFTA01423573 p.5, EFTA01423573 p.4, EFTA01423553 p.2 and EFTA01423553 p.1. The block is a single column on every sheet read, so the order above is the order printed. ⚠ Two contact-value fields sit below the address on each of those sheets and both are barred; neither is reproduced here, and no contact value for him is reproduced from any source. ⚠ Three sheets add the lineSecurities offered through Deutsche Bank Securities Inc.below the block and one does not; nothing is inferred from the difference. The address is a bank office floor, not a residence. ↩ -
The measurement, taken 2026-09-20.
"Richard Iarossi"returns 292 documents, measured twice on two independent instruments, the local corpus index and the site’s own query endpoint, which agreed exactly. ⚠ The hinge is page scope: a document counts when any one of its pages carries the phrase, so a copy list counts and a signature block on a forwarded copy counts. Name forms were measured against each other rather than assumed: the bare surname reaches 323;"Rich Iarossi"reaches 29, of which 27 lie outside the full-name form, so the two forms overlap in only 2 documents;"Iarossi, Richard"reaches 22, all of them inside the full-name form. The union of the three forms is 319, and the four remaining surname documents were opened and are the same man, reached only because the extraction damaged his forename or split it from the surname. No middle-initial form returns anything. ⚠ No second person of this surname was found in the release. In the e-mail metadata store he is the sender of 115 rows across 85 documents, 3 July 2015 to 29 November 2018, every row flagged as non-noise; 832 rows across 347 documents carry his name in the sender, To or Cc field taken together. ⚠ These are ROW counts, not documents and not distinct messages, and the subject strings quoted on this page are strings from that store. ⚠ One sender string in the store carries an e-mail address; it is not reproduced here. ⚠ Nodoc_typefigure is printed. ↩ ↩2 ↩3 ↩4 -
9 October to 1 November 2018. EFTA01423573, a seven-sheet chain carrying ten messages, subject
Epstein - negative media [I], every sheet markedClassification: For internal use only. Page stamps run EFTA01423573 to EFTA01423579, one per sheet, and the run is filed under the first. ⚠ The run is homogeneous: all seven sheets are sheets of this one chain, and sheet 1 is the newest message, not a wrapper. ALL SEVEN SHEETS WERE RENDERED AND READ AT THE IMAGE AT 700 dpi for this page, and every quotation above is transcribed from the image. The messages quoted here are on EFTA01423573 p.5 (18 October, 5:22 PM) and EFTA01423573 p.4 (22 October, 1:36 PM); the control officer’s reply is on EFTA01423573 p.3 (22 October, 2:30 PM) and the two 9 October messages are on EFTA01423573 p.7 and EFTA01423573 p.6. The double spaces inside the quotations are as printed. ⚠⚠ THE TEXT LAYER OF pp.4 AND 5 IS WRONG AND THE IMAGE GOVERNS: it lifts the second name off the Cc line and drops it into the body below the salutation, so a desk working from the extraction would read a copy recipient as the first line of the message. It also loses one of the two spaces before'Notice of Dismissal'and renders one forename on the Cc line with a letter missing. ⚠ The Sent fields on pp.3 to 7 carry no time zone; the only zone-bearing stamp in the run is on p.1, which prints-0400. ⚠⚠ The linked complaint on p.7, and the attached ‘Notice of Dismissal’ dated 10/5/18, are NOT in this document and were not read; nothing on this page describes their contents, and the link is not reproduced. ⚠ Contact-value fields are barred on every sheet and none is reproduced here. ⚠⚠ No document read for this page records any answer to the control officer’s four questions, any decision on the remediation, or what the 2 October 2017 approval said. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 -
5 to 10 October 2018. EFTA01423553, a two-sheet chain carrying four messages, subject
Wiring limit increase[I], the three internal messages each markedClassification: For internal use only. Page stamps are EFTA01423553 and EFTA01423554. BOTH SHEETS WERE RENDERED AND READ AT THE IMAGE AT 700 dpi, and every quotation above is transcribed from the image. The chain, oldest first: Iarossi to two colleagues,Friday, October 05, 2018 2:07 PM, on EFTA01423553 p.2; the reply ofFriday, October 05, 2018 2:21 PM, Iarossi’s message ofTuesday, October 09, 2018 4:42 PMand the approval ofWed, 10 Oct 2018 09:56:15 -0400, all on EFTA01423553 p.1. The double spaces inside the quotations are as printed. ⚠ The produced sheet breaks two words across a line boundary, and the text layer of EFTA01423553 p.1 makes that worse: it renders the last sentence of the approval asYou also need a business lead (e.g., Andrew Gallivan) to . pprove., turning the brokenainto a full stop, and it renders one recipient’s name asA::theay West ern. The image governs on both, and the damaged strings are given here so that a later reader meets them where they occur. ⚠ The subject line reads[I]in square brackets at the image and(I)in the extraction; the bracket form given above is the image’s. ⚠ The bracketed markings in these subject lines are the bank’s own and are not expanded, because no document read here expands them. ⚠ The form referred to in every message is an attachment and is not in this document. ⚠ Contact-value fields are barred on both sheets and none is reproduced here. ⚠⚠ No document read for this page records whether the wire limit was raised. ↩ ↩2 ↩3 ↩4 -
Absences, each scoped. No allegation against him was found in the release read for this page. ⚠⚠ This is a narrow check against 292 documents in which the desk opened two, both of them at the image on every sheet. It ran no systematic adverse sweep and searched none of the derived stores beyond the e-mail metadata store. ⚠ A deeper pass is owed, and this page records the debt rather than implying it does not exist. The three-instrument check is narrower still and is stated exactly: the surname was queried against the text of the Department of Financial Services consent order of 6 July 2020 (EFTA00151495), the first amended class action complaint against the bank (EFTA00161958) and the bank’s presentation of 12 September 2019 to the United States Attorney’s Office (EFTA01681865), and returns nothing in any of the three. ⚠ That is a query against those three documents’ extracted text and no page of any of them was rendered for this check. ↩ ↩2