THE BURNED OVER DISTRICT

All banks have some mechanism in place to watch for illegal transactions and maintain compliance with the laws. The larger the bank, the more people in place to watch. But as the Deutche Bank experience with Trump & Co illustrates, big profits can get in the way.

Suspicious activity reports are at the heart of the federal government’s efforts to identify criminal activity like money laundering and sanctions violations. But government regulations give banks leeway in selecting which transactions to report to the Treasury Department’s Financial Crimes Enforcement Network.

Lenders typically use a layered approach to detect improper activity. The first step is filtering thousands of transactions using computer programs, which send the ones considered potentially suspicious to midlevel employees for a detailed review. Those employees can decide whether to draft a suspicious activity report, but a final ruling on whether to submit it to the Treasury Department is often made by more senior managers.

In the summer of 2016, Deutsche Bank’s software flagged a series of transactions involving the real estate company of Mr. Kushner, now a senior White House adviser.

Ms. McFadden, a longtime anti-money laundering specialist in Deutsche Bank’s Jacksonville office, said she had reviewed the transactions and found that money had moved from Kushner Companies to Russian individuals. She concluded that the transactions should be reported to the government — in part because federal regulators had ordered Deutsche Bank, which had been caught laundering billions of dollars for Russians, to toughen its scrutiny of potentially illegal transactions.

Ms. McFadden drafted a suspicious activity report and compiled a small bundle of documents to back up her decision.

Typically, such a report would be reviewed by a team of anti-money laundering experts who are independent of the business line in which the transactions originated — in this case, the private-banking division — according to Ms. McFadden and two former Deutsche Bank managers.

That did not happen with this report. It went to managers in New York who were part of the private bank, which caters to the ultrawealthy. They felt Ms. McFadden’s concerns were unfounded and opted not to submit the report to the government, the employees said.

Ms. McFadden and some of her colleagues said they believed the report had been killed to maintain the private-banking division’s strong relationship with Mr. Kushner.

After Mr. Trump became president, transactions involving him and his companies were reviewed by an anti-financial crime team at the bank called the Special Investigations Unit. That team, based in Jacksonville, produced multiple suspicious activity reports involving different entities that Mr. Trump owned or controlled, according to three former Deutsche Bank employees who saw the reports in an internal computer system.

Some of those reports involved Mr. Trump’s limited liability companies. At least one was related to transactions involving the Donald J. Trump Foundation, two employees said.

Deutsche Bank ultimately chose not to file those suspicious activity reports with the Treasury Department, either, according to three former employees. They said it was unusual for the bank to reject a series of reports involving the same high-profile client.

Mr. Trump’s relationship with Deutsche Bank spans two decades. During a period when most Wall Street banks had stopped doing business with him after his repeated defaults, Deutsche Bank lent Mr. Trump and his companies a total of more than $2.5 billion. Projects financed through the private-banking division include Mr. Trump’s Doral golf resort near Miami and his transformation of Washington’s Old Post Office Building into a luxury hotel.

When he became president, he owed Deutsche Bank well over $300 million. That made the German institution Mr. Trump’s biggest creditor — and put the bank in a bind.

Needless to say, all the perps have denied any wrong doing. Private Bankers can have an oversized influence on bank management because they generally bring in yuge profits. And the US regulators don't have a great track record of effective punishment to financial corporate wrong doers. But this is a lot of smoke at a bank that had already been burned big time by the Trumpian 'Business Genius'.