Richard Kahn** triggered Deutsche Bank's anti-money laundering alert system three times in fourteen months — and each time, the bank kept his accounts open.
Grand jury documents unsealed from the Southern District of New York reveal that Deutsche Bank's AML compliance team ran Know Your Customer checks on Kahn in July 2017, May 2018, and August 2018. All three produced RDC alerts — the bank's internal flag for clients requiring escalated review. All three are stamped "CONFIDENTIAL — PURSUANT TO FED. R. CRIM. P. 6(e)."
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Three Alerts, One Client, Fourteen Months
The first KYC was prepared July 21, 2017 by Deutsche Bank's BIS-Research unit under AML Compliance guidelines. The cover sheet notes: "Significant negative media results may require escalation to senior business, Legal and Compliance management." RDC returned an alert for Kahn — KYC reference 1804531.
Ten months later, on May 31, 2018, Deutsche Bank ran a second check. Again, an RDC alert fired — this time tied to KYC 01946825, with two separate Kahn entries both returning hits. FIRCOSOFT — Deutsche Bank's sanctions screening system — showed no hit. The bank cleared him.
On August 17, 2018, a third analyst, Mamta Choudhary, ran a fresh KYC on Kahn. RDC flagged him again. The form notes "Review by Legal May be Required" under Court Cases. Deutsche Bank retained him as a client.
The Foundation He Shared with Epstein
A 45-page background report compiled by investigators on July 9, 2019 — the same day Kahn cancelled a $14,950,000 Charles Schwab wire — maps his corporate affiliations in detail.
Among them: The C.O.U.Q. Foundation, Inc., a private charitable entity with three listed directors. Jeffrey Epstein held the title "DP" — Director Principal. Darren Indyke, Epstein's personal attorney and estate executor, held "PVS." Richard Kahn held "DT."
"JEFFREY E EPSTEIN Title: DP / 6100 RED HOOK QUARTER B-3" — Individual Report for Richard D. Kahn, July 9, 2019 (vol00010-efta01265841-pdf, p. 10)
The Virgin Islands address on Epstein's C.O.U.Q. entry is the same used for his registered entities at Zorro Ranch and Little St. James operations.
A Corporate Network Run from One Apartment
The individual report flags Kahn for "Residential Address Used as a Business Address" — a quick-analysis warning triggered when the same address serves as both personal residence and corporate registration.
Investigators found at least five entities connected to Kahn's Upper East Side address:
HBRK Associates Inc. — registered to Kahn at 1365 York Avenue, Apt. 28. Separate documents in the 21,286-file archive show HBRK processed payments exceeding $555,000 to socialite Peggy Siegal, who arranged Epstein's meetings with senior media and finance figures.
K&F Capital Corp. — Kahn listed as Treasurer. Registered at 10 Esquire Road, Westchester.
RDK Asset Management Inc. — Kahn as President. Also registered at his York Avenue address.
Foundation for Child Development — Kahn listed as Vice-Chairman alongside Barbara P. Robinson as Chairman. The foundation is a New York philanthropy focused on early childhood policy.
The Compliance Trail
Each of the three Deutsche Bank KYC forms is marked with a SDNY grand jury confidentiality designation under Federal Rule of Criminal Procedure 6(e). That means the documents were produced in connection with a federal grand jury investigation — not merely seized in a civil discovery process.
The July 2017 review (DB-SDNY-0023186) was prepared by analyst Reena Chandwani. The May 2018 review (DB-SDNY-0023942) was prepared by Vikram-D Singh. The August 2018 review (DB-SDNY-0026276) was prepared by Mamta Choudhary.
All three list the same subject: "Richard Kahn, PWM" — Private Wealth Management, the Deutsche Bank division that handled Epstein's core accounts.
Epstein's arrest came July 6, 2019. Three days later, on July 9, a confidential 45-page intelligence report on Richard Kahn was completed. That same afternoon, a $14,950,000 wire from a Charles Schwab account was cancelled.
All individuals mentioned are presumed innocent unless proven guilty in a court of law.
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This analysis references publicly released documents from the Epstein case archive. All individuals mentioned are presumed innocent unless convicted in a court of law. Language such as “documents indicate” reflects what appears in source materials, not conclusions of guilt. Readers are encouraged to review the cited source documents directly.