Jeffrey Epstein and Deutsche Bank: The Intersection of Human Trafficking, Customer Due Diligence and Compliance
OVERVIEWIn July 2020 the New York Department of Financial Services (DFS) hit Deutsche Bank with a $150 million penalty, stemming in part from the bank’s failures to monitor and report millions of dollars of transactions through accounts the bank held for convicted sex offender Jeffrey Epstein. The enforcement action capped off the shocking and sordid Epstein case. The disgraced financier with ties to the rich and powerful was charged with trafficking underage girls for sex in 2019, after nearly 15 years of previous criminal investigations, a conviction, and numerous civil cases tied to human trafficking. Epstein’s high-profile arrest and ultimate demise drew lots of media attention, but less well-attended were the lessons for financial institutions from the twisted saga. In this presentation, two compliance experts unpack the NY DFS enforcement action against Deutsche Bank and explore its implications for customer due diligence programs, human trafficking red flags, and dealings with high net worth customers. Join us to learn:
- The Importance of Putting the Business on the Record for Maintaining High Net Worth High Risk Customers
- Managing Ongoing Due Diligence Requirements for High Risk Customers including Negative News and Adverse Media
- Understanding the Significance of Governance in Managing High Risk Customers
- How Many Red Flags is Too Many?