EFTA01413743: Deutsche Bank’s Haze Trust Art Transfer Inquiry (2016)

Snapshot

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Key Takeaways

• The original inquiry asked for the source of an incoming payment and the purpose, beneficiary relationship and source of wealth associated with outgoing payments. It records a bank review, without establishing that the transactions were unlawful.
• The two November 23 payments were $25 million to AP Narrows Holding LP/BMO Trustee and $5 million to LDB 2011 LLC/BMO Trustee, both listed through a CDEC clearing account at Bank of America.
• Vahe Stepanian’s December 2 response described an art purchase, while the continuation relayed a client explanation about escrow pending delivery. The chain does not name the artworks or contain a delivery receipt.
• The December 5 compliance response explicitly rejected the private-bank wire explanation as an answer to the HSBC question. Those incoming payments must remain separate.
• A December 21 reply in the expanded chain attributes the HSBC payment to a King Street Capital distribution. It does not contain a compliance closure decision.

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What the document contains

EFTA01413743 is a reverse-chronological email chain about the Haze Trust at Deutsche Bank. Its first page is a December 20, 2016 follow-up headed as a third request. The original December 2 inquiry begins near the end of the file, followed by the three transaction entries and the questions compliance wanted answered.

The inquiry describes the bank’s Actimize monitoring process as identifying transaction patterns that require further research. It requests a complete response within seven business days. That language explains why compliance contacted the banking team; the document does not show an investigative finding that the listed funds were criminal proceeds.

The correspondence identifies Stewart Oldfield as the primary relationship manager. Zbynek Kozelsky, Vahe Stepanian and Cynthia Rodriguez supply or seek information in the chain, while Danya Friedman writes on behalf of the compliance inquiry team. Being named as a recipient or copied on a message does not establish that a person authorized a transfer or endorsed every explanation in the thread.

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The three transactions in the inquiry

The incoming entry and the outgoing entries are transaction details reproduced inside an inquiry, rather than a complete account ledger. The two outgoing amounts sum to $30 million. Adding the incoming payment to those outgoing amounts would combine money moving in opposite directions and would not measure a single purchase, loss or amount laundered.

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December 2: the art and escrow explanations

Kozelsky’s 11:03 a.m. message asks Stepanian to follow up and identifies the reason as an art purchase. Stepanian’s 11:11 a.m. response brings Oldfield into the exchange as the relationship manager who could confirm the information. In the continuation, Stepanian says that, according to a conversation with the client, the beneficiary was an escrow account that would hold the cash pending delivery of the art. He asks Oldfield for the private-bank customer information that he believed covered the client’s source of wealth.

Oldfield’s 11:17 a.m. reply says Rodriguez will return on Monday and provide the documents. At 11:21 a.m., compliance separates the questions: it asks whether the response covers both outgoing payments, reiterates the need to identify the incoming payment’s ultimate originator and explains that the Haze Trust’s customer information is already held. It asks instead for the beneficiaries’ source of wealth, if available.

Kozelsky’s 11:23 a.m. explanation describes funds moving internally from the client’s private-bank account into the securities account. Compliance’s 11:36 a.m. reply asks which originating account he means, says the transaction could not be located in the named private-bank systems and asks why an internal transfer would be routed through HSBC. The chain therefore records a mismatch between the transaction being explained and the transaction compliance was trying to identify.

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December 5: the separate $23 million wire

Rodriguez’s December 5 email describes funds originating with Southern Trust Company, Inc., passing through Bank of New York and being placed in the securities account for an art purchase. She identifies Jeffrey Epstein as the originating client and purchaser in that explanation. Her statement provides the banking team’s account of that transfer; the message is not an executed bill of sale or proof of the ownership and delivery of any particular artwork.

Compliance’s reply at 12:05 p.m., continued on the next page, says the explanation concerns a different wire. It acknowledges seeing a $23 million incoming transfer from the private-bank account and says that was never the transfer being questioned. It repeats the October 27 HSBC entry for $6,186,980.68 and asks where those funds originated.

That distinction prevents two errors: attributing the HSBC payment to Southern Trust on the strength of Rodriguez’s explanation, or treating the $23 million transfer as an additional transaction in the original three-item alert. The email does not provide a date for that $23 million private-bank wire.

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December 14 and 20: the follow-ups

The December 14 message, continued on page 2, follows up on the inquiry. The December 20 message at the start of the file labels itself the third request and seeks an immediate response. This 11-page version stops at that follow-up. It does not contain the subsequent replies or a closing compliance determination.

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The later December 21 reply

The expanded chain, EFTA01414241, adds replies beyond this document’s endpoint. On December 20, Rodriguez distinguished the brokerage inflow from private-bank funds; compliance reiterated the HSBC question and Stepanian said the answer was unknown. Oldfield offered a general description of the client’s wealth.

Kozelsky’s December 21 message reports that he and Oldfield spoke with the client and describes the $6.2 million payment as a capital distribution from King Street Capital, one of the client’s partnership investments. This is a reported client explanation. The expanded chain supplies neither supporting investment statements nor a subsequent compliance acceptance or closure. Its later reply prevents the earlier third-request message from being treated as the final available response.

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What the record establishes and leaves open

• The monitoring inquiry establishes that compliance sought information about identified transfers. It does not itself establish money laundering, art fraud or a finding of personal misconduct by any named employee or organization.
• The art-purchase response and escrow explanation establish what bank personnel told compliance. They do not identify the artist, work, ultimate owner, delivery date or completed terms of the purchase.
• The follow-up questions distinguish the client’s customer information from information requested about beneficiaries. The underlying customer files are not included in this record.
• The beneficiary labels do not disclose the full ownership or governance of AP Narrows Holding LP, LDB 2011 LLC or the referenced escrow arrangement. No ownership inference follows solely from their names.
• Repeated requests show that information was still being sought at the times recorded. The correspondence alone cannot establish the bank’s final disposition, whether a regulatory report was filed, or whether later documentation independently verified the explanations.

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Evidence Appearances

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Document image

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Source List

• EFTA01413743 through EFTA01413753: the 11-page copy preserved in EpsteinWiki’s existing PDF attachment. Page references in this article use that copy.
• EFTA01414241 through EFTA01414257: the expanded 17-page chain, available through a third-party PDF mirror. The later-reply discussion uses its extracted text; the copy’s redacted fields are not reconstructed.

For related coverage, see the EpsteinWiki art-collection guide and the Stewart Oldfield profile. This entry focuses on the inquiry and its replies.