TLDR
Richard Kahn made three cash withdrawals from HBRK Associates accounts totaling $62,400 in early 2019: $4,400 on February 1, $8,000 on April 22, and $50,000 on May 7. The $50,000 withdrawal triggered a mandatory Currency Transaction Report (CTR — filed automatically for cash transactions over $10,000) just 60 days before Epstein's July 6 arrest. The escalating pattern — each withdrawal larger than the last — suggests accelerating cash positioning as risk indicators mounted (TD Bank, 2019).
Three Withdrawals, Ascending
The TD Bank Suspicious Activity Report (SAR — a report banks must file when they detect potential financial crime) documents three cash withdrawals by Richard Kahn from HBRK Associates accounts at TD Bank in the first half of 2019. The amounts tell their own story: $4,400 on February 1, $8,000 on April 22, and $50,000 on May 7. Each withdrawal was larger than the previous one. The total: $62,400 in cash over 95 days (TD Bank, 2019).
The first two withdrawals — $4,400 and $8,000 — both fell below the $10,000 CTR threshold. At these amounts, the bank was not required to file a CTR, and the withdrawals would not automatically appear in FinCEN's (the Financial Crimes Enforcement Network, the Treasury bureau that collects financial intelligence from banks) transaction database. The amounts were not structured at a single round number like ATTORNEY-1's 97 withdrawals of exactly $7,500 at Deutsche Bank, but they shared the same property: staying below the reporting line.
The third withdrawal abandoned that discipline entirely. On May 7, 2019, Kahn withdrew $50,000 in cash from the HBRK Associates account — five times the CTR threshold. This triggered the mandatory filing that the first two withdrawals had avoided.
The Timing
May 7, 2019 was 60 days before Jeffrey Epstein's arrest on July 6, 2019. Whether Kahn had specific knowledge of the pending arrest is unknown. What is known is the broader context: Deutsche Bank had been systematically closing Epstein-related accounts since February 2019 (TD Bank, 2019). Funds were migrating from Deutsche Bank to TD Bank. The entire financial infrastructure was in motion.
The HBRK Associates TD Bank accounts were themselves recently opened. Account 4332212771 was opened on April 18, 2019 — just four days before the second cash withdrawal and 19 days before the $50,000 withdrawal. Account 4332216963 was opened on February 5, 2019, four days after the first cash withdrawal. Both accounts received substantial wire transfers: $3.74 million into account 4332212771 across five wires, and $947,838 into account 4332216963 (TD Bank, 2019).
Opening new accounts, receiving millions in wires, and making escalating cash withdrawals — all within a five-month window in early 2019 — describes a pattern of rapid financial repositioning.
The Contrast with ATTORNEY-1
ATTORNEY-1's structuring (deliberately breaking large cash transactions into smaller ones to avoid bank reporting requirements) at Deutsche Bank was a slow, methodical operation: 97 identical withdrawals at $7,500 each, two to three per month, over four years. The pattern was designed for endurance — to sustain a cash supply indefinitely without triggering a single report. It worked for four years (NYDFS, 2020).
Kahn's three withdrawals in 2019 exhibit the opposite characteristics. The amounts are irregular ($4,400, $8,000, $50,000). The frequency is compressed (three withdrawals in 95 days versus 97 in four years). The final withdrawal does not merely approach the reporting threshold — it exceeds it by a factor of five.
This contrast suggests different operational postures. ATTORNEY-1's pattern was steady-state maintenance — the cost of doing business, conducted with the patience that suggests confidence in continued access. Kahn's pattern was an acceleration — the behavior of someone who either needs cash urgently or believes the window for obtaining it is closing.
Who Kahn Was
Richard Kahn was not a peripheral figure in the Epstein financial network. He served as Epstein's accountant, co-executor of the estate (alongside Darren Indyke), co-trustee of the Butterfly Trust, and sole authorized signer on HBRK Associates accounts. His roles gave him fiduciary access to multiple entity accounts across the corporate structure (PAPER TRAIL Project, 2026).
HBRK Associates itself was a financial management entity. In addition to the cash withdrawals, its accounts disbursed tuition payments ($4,300) and accommodation payments ($20,040) for a redacted female student, $100,000 to White and Case LLP, and $1.66 million received from Southern Country International's Charles Schwab account. The entity functioned as a financial control node — receiving wires from Epstein entities and directing funds to a mixture of legal, educational, and personal purposes (TD Bank, 2019).
Kahn's position as sole signer meant he had unilateral authority over these funds. No co-signature was required. No secondary approval was needed. The cash withdrawals were not someone taking money from an account they shared — they were the sole authorized person exercising exclusive control.
$62,400 in Context
Sixty-two thousand four hundred dollars is not a large sum relative to the millions flowing through HBRK Associates accounts. It is less than 2% of the $3.74 million that entered the primary HBRK account. But cash has a specific property that wire transfers do not: it is untraceable after withdrawal. Once the $50,000 left the TD Bank teller window, it ceased to exist in any electronic record. Its subsequent use — whether for legal fees, personal expenses, witness payments, or anything else — generates no transaction record.
That property is what makes pre-arrest cash positioning significant. In the weeks before a federal arrest that would freeze related accounts, cash is the one form of value that survives the freeze. It can pay lawyers who will not accept wire transfers from frozen accounts. It can fund living expenses when credit cards are flagged. It can accomplish whatever its holder intends, with no receipt and no record.
The CTR filing on the $50,000 withdrawal documents the cash leaving the bank. It does not document where the cash went. That information, like much in this corpus, exists in the 42% of pages that have not been released.
References
NYDFS. (2020). Consent order: In the matter of Deutsche Bank AG. New York Department of Financial Services. https://www.dfs.ny.gov
PAPER TRAIL Project. (2026). Corroboration report [Data set].
PAPER TRAIL Project. (2026). Entity ownership research [Data set].
TD Bank. (2019). Suspicious Activity Report (BSA-31000155070501). Filed October 1, 2019.