Epstein Data Wiki

Xavier Avila

Properties2
tagsperson, deutsche-bank, kyc, southern-financial, derivatives, 2018
aliasesXavier Avila, Avila, Xavier

8 min read

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

A Deutsche Bank markets figure who handled trades for an Epstein entity, and who in April 2018 was on an internal thread headed “KYC Breach” about that entity. No allegation against him was found anywhere in the release, and none is made here. ⚠⚠ The page does not say why the trade was moved, because the documents do not.

WhoXavier Avila, at Deutsche Bank; the release shows him on markets and derivatives threads1
In the release955 documents, 1,576 pages2
His own messages469 sender rows under his own name, concentrated in 2017 and 20182
⭐ The actOn 16 April 2018, on a thread whose subject line reads “KYC Breach_SOUTHFINANMD_Southern Financial, LLC_FFT Location”, he asked colleagues: “Shawn, MO, is it ok to move this trade to London pls?” A colleague answered: “I would re-book to London if the desk agrees.”3
⚠ Not himReinaldo Avila da Silva, a different person, accounts for 69 of the surname’s sender rows2

Xavier Avila appears in the released files as a Deutsche Bank markets person whose work touches Southern Financial, LLC, an Epstein entity. The thread that matters is headed with the bank’s own compliance language.

16 April 2018: “KYC Breach”

The sheet is one page and was read at the image.3 Its subject line, repeated down the chain, is:

RE: KYC Breach_SOUTHFINANMD_Southern Financial, LLC_FFT Location [I]

At 7:44 AM Avila opened the thread to colleagues. At 9:03 AM one of them replied, under the marking “Classification: For internal use only”:

I would re-book to London if the desk agrees.

At 12:55 PM Avila wrote:

Shawn, MO, is it ok to move this trade to London pls?

⚠⚠ WHAT THIS DOES AND DOES NOT ESTABLISH. It establishes that the bank had identified a know-your-customer breach in connection with Southern Financial, LLC, that the thread’s subject line ties that breach to the trade’s Frankfurt booking location, and that re-booking the trade to London was floated among the bankers.

⚠⚠⚠ AND THE THREAD’S OWN ENDING CUTS AGAINST THE OBVIOUS READING, WHICH IS WHY THE DESK WENT BACK AND READ THE REST OF IT. The whole episode is two days, 16 and 17 April 2018, across 32 documents, not an open-ended series. It closes with the London cross-currency desk saying the opposite of what a move to London would imply:

In general, everything should face FFT and other booking centres are only used in exceptional circumstances I believe

and with Avila writing “Done, thanks” and asking “who can help us with FFT extensions”: that is, asking how to extend the Frankfurt arrangement, not how to leave it.4

⚠ The page therefore does NOT say a trade was moved to another jurisdiction to escape a compliance flag. A booking location changes for ordinary regulatory, entity and desk-coverage reasons, the London desk itself calls Frankfurt the default, and ⚠ no document read for this page says what finally happened to the trade.

⚠ Several other Deutsche Bank people are on the thread. They are not named here, because nothing on this page turns on the distribution list.

What the 955 documents are

A count this size has been an artefact three times on this wiki, so the shape was measured first.2

  • 1,576 pages across 955 documents, 1.65 pages per document. ⚠ That ratio is high for e-mail and the desk checked it: 861 of the documents are typed as e-mail headers, and the ratio comes from a small number of long financial documents, the heaviest running to 25 pages. It is not a running head and not a photographed book.
  • The rest of the population types as equity swaps (13), trust documents (10), research reports (9) and scanned images.
  • ⚠⚠ The surname is two people. Sender rows matching Avila include 69 for Reinaldo Avila da Silva, who is a different person. Xavier Avila’s own rows are 469, and no figure on this page uses the bare surname.
  • His traffic is concentrated late: 2009 50 · 2010 24 · a near-gap to 2016 · 2017 107 · 2018 367 · 2019 1.

What this page does not say

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

⚠⚠ NOTHING HERE ALLEGES THAT HE BREACHED ANY RULE. The phrase “KYC Breach” is the bank’s own subject line, not a characterisation by this page, and a compliance flag raised inside a bank is evidence that the bank’s controls produced a flag. ⚠ Whether Deutsche Bank’s handling of Epstein as a client was adequate is a separate question, addressed at Deutsche Bank, and this page does not resolve it or attribute it to any individual.

Footnotes

Footnotes

  1. Identification. ⚠ No document read for this page states his title, desk or division. The page calls him “at Deutsche Bank, on markets and derivatives threads”, which is what the subject lines and the internal distribution lists support. ⚠ A sister page was corrected this week for taking a job title from a colleague’s signature block, and this page states none. ↩

  2. The measurement. "Xavier Avila" returns 955 documents across 1,576 pages, 1.65 pages per document. ⚠ That ratio is roughly fifty per cent above this wiki’s usual e-mail population and was therefore tested: documents.doc_type types 861 of the documents as email.header, with financial.equity_swap 13 · image.scan 10 · financial.trust 10 · research.report 9 · image.photo 7 ⚠⚠ The specialised financial doc_type labels are NOT reliable and these counts are not relied on anywhere on this page: the desk measured the classifier at 52% for financial.equity_swap and 5% for court.plea_agreement against a 40-document sample each, while email.header measured 100%. Only the e-mail figure above is safe to quote.; the five heaviest documents carry 25, 22, 22, 21 and 21 pages and account for the excess. No running head and no photographed book. ⚠ The hinge is page scope: a document counts when any one of its pages carries the phrase. ⚠⚠ The bare surname must not be used for this subject: Avila sender rows include 469 for Xavier Avila and 69 for REINALDO AVILA DA SILVA, a different person, plus small numbers for others. Every figure on this page is keyed to the full name. By year, his own rows run 2009 50 · 2010 24 · 2011 1 · 2012 2 · 2015 6 · 2016 3 · 2017 107 · 2018 367 · 2019 1. ⚠ No deduplicated message total is stated. ↩ ↩2 ↩3 ↩4

  3. 16 April 2018. EFTA01401922 p.1, read at the image at 700 dpi, carrying three messages of that morning: Avila at 7:44 AM, a reply at 9:03 AM under Classification: For internal use only, and Avila at Mon, 16 Apr 2018 12:55:22 -0400. The subject line is reproduced exactly as printed, underscores and the trailing [I] included. ⚠ FFT is a booking-location code and the page does not expand it beyond noting it is the trade’s booking location. ⚠ “MO” in Avila’s message is not expanded, because the sheet does not expand it. ⚠ The page names only the two participants who speak and reproduces no e-mail address from this sheet. Copies of the same April 2018 thread exist at EFTA01399702, EFTA01363005 and EFTA01406842; none was separately rendered and nothing here rests on them. ⚠ The desk initially opened ONE message of this thread and has since read the rest of its ends. The subject line appears on 55 sender rows across 32 distinct documents, every one dated 16 or 17 April 2018, a two-day episode, not a running series, which an earlier version of this page did not establish. ↩ ↩2

  4. The close of the thread, 17 April 2018. EFTA01406948 p.1, read at the image at 700 dpi: Jimmy-H Xu, Cross Currency Swap Trading, Deutsche Bank AG Filiale London, CB&S Markets, Winchester House, Tue, 17 Apr 2018 02:53:54 -0400, under “Classification: For internal use only”. His whole message is the two quoted lines. Avila’s message of 17 April 2018 02:30 sits beneath it and reads “Done, thanks. … Are all the XCCYs generally booked and clients KYCed in DB AG FFT? What about EUR and GBP vanilla and inflation swaps? We might have some of those coming. Mat/Nina, who can help us with FFT extensions, same NY CMs?”, read from the text layer of EFTA01363054. ⚠ “I believe” is Xu’s own hedge and is quoted with it. ⚠ His statement is about general practice and is not a decision about this trade, and nothing read records the trade’s final booking. ⚠ No e-mail address or telephone number from this sheet is reproduced here. ↩

  5. Absences, each scoped. No allegation against him was found in the release read for this page. ⚠⚠ This is a narrow check and is stated as one: the desk read his subject lines and opened one thread of 955 documents. It did not run a systematic adverse sweep, did not search the six derived stores, and did not open the 35 remaining “KYC Breach” messages, the equity-swap documents or the research reports. A subject with 469 authored messages inside a bank’s markets correspondence deserves a deeper pass than this page has had, and that is recorded rather than dressed as a finding. ↩

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