TLDR
Gratitude America Ltd., a USVI-based 501(c)(3) foundation (a tax-exempt charitable organization under U.S. tax law), received $10 million from BV70 LLC — a Leon Black entity — peaking at $10.2 million in assets. When Deutsche Bank's compliance committee finally required external due diligence on the foundation, Epstein resigned and the account request was withdrawn. It is the only documented instance where the ARRC (Americas Reputational Risk Committee — Deutsche Bank's internal panel for reviewing clients who could damage the bank's reputation) conditions actually blocked an Epstein account opening.
The Foundation
Gratitude America Ltd. was established in September 2012 in the U.S. Virgin Islands as a 501(c)(3) private grantmaking foundation (NTEE classification T20) with EIN 66-0789697 (Internal Revenue Service, n.d.). Its registered address was 9053 Estate Thomas Suite 101, St. Thomas, VI 00802. The officer structure followed the standard Epstein pattern: Epstein as President (2012-2015), Kahn as President (2015 onward), Indyke as VP and Treasurer, and Kellerhals as Secretary and Treasurer (PAPER TRAIL Project, 2026a).
The foundation's public tax filings are available through ProPublica's Nonprofit Explorer. They show a straightforward financial trajectory: a large initial donation, modest activity, and declining assets. By fiscal year 2022, total assets stood at $8,175,884 with zero revenue — a foundation that was slowly spending down its funds with no new inflows (ProPublica, n.d.).
The $10 Million Donation
The foundation's funding came from a single source: BV70 LLC, a Leon Black entity, which donated $10 million (ProPublica, n.d.; PAPER TRAIL Project, 2026a). Leon Black, co-founder and former CEO of Apollo Global Management, would later face public scrutiny when an independent review disclosed that his total payments to Epstein reached $158 million across various arrangements. The $10 million Gratitude America donation was one component of a much larger financial relationship.
Peak assets reached $10.2 million in 2015, shortly after the full donation was received (Form 990-PF, 2015). The foundation operated as a private grantmaking organization — it gave grants to other entities rather than conducting direct charitable activities.
The Deutsche Bank Account That Was Not
In January 2016, ACCOUNTANT-1 requested a brokerage account at Deutsche Bank for Gratitude America (NYDFS, 2020, ¶44). This request triggered the one compliance mechanism that actually worked during the Epstein relationship: the ARRC ordered external due diligence (a thorough background investigation) on the foundation.
The ARRC's due diligence requirement was the only documented instance where Deutsche Bank's compliance architecture produced a meaningful obstacle to an Epstein-related account opening. For every other account — across the 40-plus that were opened — the May 2013 Approval Email served as the blanket authorization. But the Gratitude America request came three years later, under different personnel, and the ARRC asserted its authority (NYDFS, 2020, ¶44).
Epstein's response was to resign from the foundation before the due diligence was completed. The account request was withdrawn. No due diligence report was ever produced (NYDFS, 2020, ¶44).
What the Withdrawal Reveals
The sequence — request, due diligence requirement, resignation, withdrawal — reveals the operational response to genuine compliance scrutiny. When Deutsche Bank cleared alerts using the Approval Email, the system posed no obstacle. When the ARRC imposed an actual investigative requirement, the response was not to cooperate with the review but to remove the problematic individual and cancel the request.
This pattern suggests awareness that external due diligence would likely produce unfavorable findings. A foundation with legitimate charitable operations would benefit from a compliance review — it would demonstrate clean governance and proper use of funds. The decision to withdraw rather than submit to review implies the opposite.
The Epstein-to-Kahn Transition
Epstein served as President from the foundation's establishment in 2012 through 2015 (PAPER TRAIL Project, 2026a). Kahn assumed the presidency in 2015 and continued beyond Epstein's death. This transition occurred before the Deutsche Bank account request, meaning that by January 2016, Epstein was no longer an officer of the foundation.
The ARRC's due diligence requirement suggests that despite the officer change, Deutsche Bank recognized that Gratitude America remained within Epstein's sphere of influence. The name change on the filing did not change the compliance risk assessment — or at least, not enough to waive the due diligence requirement.
The USVI Settlement
Gratitude America was named in the USVI v. Estate $105 million settlement in December 2022, alongside Southern Trust, Financial Trust Company, and seven other Epstein entities (PAPER TRAIL Project, 2026a). The foundation's inclusion in the settlement confirmed its role within the broader corporate network, despite its status as a tax-exempt charitable organization.
The settlement did not dissolve the foundation. As of fiscal year 2022, it continued to hold $8.1 million in assets under Kahn's presidency (ProPublica, n.d.). Whether it continues to make grants, what organizations receive those grants, and how the foundation's governance has changed post-settlement are questions not answered by the public corpus.
References
Form 990-PF. (2015). Gratitude America Ltd. (EIN 66-0789697). Internal Revenue Service.
Internal Revenue Service. (n.d.). Gratitude America Ltd. (EIN 66-0789697, NTEE T20, established September 2012).
New York Department of Financial Services. (2020, July 6). Consent order: Deutsche Bank AG (Case Reference 1082293). NYDFS. Paragraph 44 (ARRC due diligence, Epstein resignation, account withdrawal).
PAPER TRAIL Project. (2026a). Gratitude America officer structure, BV70 donation, and USVI v. Estate settlement [Research file]. ENTITY_OWNERSHIP.md.
ProPublica. (n.d.). Gratitude America Ltd. Nonprofit Explorer. https://projects.propublica.org/nonprofits/