Brian Benczkowski

Epstein network used Alfa Bank for wire transfers: DOJ Vol 11 documents show multiple wire transfer instructions routing Epstein-related payments through Alfa Bank Moscow (SWIFT: ALFARUMM) via Bank of New York Mellon and Wells Fargo as US correspondents. EFTA02629196 shows a Jan/Feb 2019 wire to Alfa Bank handled by Bella Klein. LMSBAND corpus contains at least 10 Alfa Bank wire instructions (EFTA01357941, EFTA01365166, EFTA01363148 etc.). This creates an additional layer to the Benczkowski conflict: not only did he represent Alfa Bank at K&E, but Alfa Bank was an actual financial intermediary used by the Epstein operation for international wire transfers.

Benczkowski's spouse runs lobbying firm West Front Strategies LLC with 20+ filings. While Benczkowski headed DOJ Criminal Division (2018-2020), spouse's firm lobbied for Comcast, Microsoft, Expedia, Prudential Financial, T-Mobile, Walgreen, Best Buy, Republic Services, and others on issues including financial regulation, taxation, health, and telecommunications. Creates structural conflict: AAG Criminal Division potentially overseeing enforcement matters involving spouse's lobbying clients. Per ProPublica financial disclosure, spouse's firm generated $500K-$1M annually.

Benczkowski FEC donations reveal Republican operative network: While at K&E (2021-2025), donated to Tom Cotton (Senate, $10K), Adam Laxalt (Senate, $7.9K), Deb Fischer (Senate, $6.7K), James Comer (House Oversight Chair, $2K), Christina Nolan (Senate, $1K), Jesse Reising (House, $8.7K), and Ron DeSantis via Restore Our Nation PAC ($9.9K). Also donated to multiple candidates while at K&E from McLean/Arlington VA. FEC records confirm he moved from K&E to Boeing in late 2025 (began biweekly to Boeing PAC). Political donation pattern shows deep Republican establishment connections relevant to his DOJ appointment.

K&E Epstein defense cited Benczkowski's own 2007 DOJ letter: Kirkland & Ellis's submission to the Deputy AG defending Epstein (EFTA00013811) cited a November 9, 2007 letter from 'Justice Department Principal Deputy Assistant Attorney General Brian Benczkowski to the House Committee on the Judiciary' arguing that prostitution-related offenses are historically state-level crimes and 'the Department is not aware of any reasons why state and local authorities are not currently able to pursue prostitution-related crimes such that Federal jurisdiction is necessary.' K&E used Benczkowski's own words to argue Epstein's conduct should not be federally prosecuted under 18 USC 1591/2422(b)/2423(b).

Benczkowski was Chief of Staff to Deputy AG Mark Filip when Ken Starr (K&E partner) wrote to Filip lobbying to drop the Epstein federal case. Starr's letter accused prosecutors of misconduct and urged DOJ Main Justice intervention. Filip was the 33rd Deputy AG (March 2008-Feb 2009); Benczkowski became Filip's Chief of Staff in 2008 before transitioning to AG Mukasey's Chief of Staff in Aug 2008. The chain: K&E partner Starr writes to K&E alum Filip (DAG) whose Chief of Staff Benczkowski later joins K&E (2010), then becomes AAG Criminal Division (2018) overseeing the exact statutes (18 USC 1591) used to prosecute Epstein in 2019.

Benczkowski confirmation fight and narrow recusal scope: Confirmed 51-48 on July 11, 2018 after year-long delay. All Democrats opposed. Key concerns: (1) No prosecutorial experience for Criminal Division head. (2) Alfa Bank representation omitted from Senate questionnaire, only discovered in FBI background file. (3) Benczkowski said K&E confidentiality agreement prevented disclosure. (4) Recused only from Alfa Bank matters, NOT Alfa Group Consortium. (5) Refused to commit to recusal from Mueller investigation or Russia-related matters. (6) Two confidential clients on financial disclosure -- one involved in non-public investigation. Senators Whitehouse, Warner, Coons, and Durbin led opposition.

Triple ethics waiver pattern at DOJ Criminal Division: Benczkowski received ethics waiver in April 2019 to participate in Goldman Sachs 1MDB case despite K&E representing Goldman (via Mark Filip). Second waiver in November 2018 for 1MDB, third waiver in December 2019 for unspecified 'confidential criminal matter.' AG Barr also received parallel 1MDB waiver. K&E partner Filip was Goldman's lead defense counsel. Goldman paid $2.9B settlement; critics argued waivers enabled lenient treatment. Benczkowski received $847,500 severance from K&E upon joining DOJ.

Criminal Division jurisdiction overlap with Epstein prosecution: The DOJ Criminal Division's Child Exploitation and Obscenity Section (CEOS) is responsible for federal child sex trafficking cases under 18 USC 1591 -- the exact statute used to indict Epstein in July 2019. CEOS works in partnership with US Attorney offices on these cases. Benczkowski headed the Criminal Division from July 2018 to July 2020, encompassing the entire SDNY Epstein prosecution (indictment July 6, 2019 through death Aug 10, 2019 and continued investigation). Zero results for 'Benczkowski' in the entire 331K+ DOJ document corpus is investigatively significant -- the AAG overseeing the division responsible for sex trafficking left no documented trace in the case files.

Benczkowski joined Boeing (Sept 2025) as VP/Assistant General Counsel for Government Operations. Boeing was the subject of the 'Epstein Deal' comparison: Mark Filip (K&E partner, Benczkowski's former boss at DOJ) represented Boeing in the 737 MAX DPA (.6M penalty). Legal scholar Paul Cassell argued Boeing's DPA Statement of Facts was ghostwritten by Boeing attorneys, 'in the same clubby fashion' as the Epstein NPA. Filip authored the 'Filip Memorandum' governing DPAs while Deputy AG. Boeing's DPA was filed Jan 2021, breached in 2024, then resolved via NPA in May 2025. Benczkowski was hired 4 months after the NPA resolution to manage Boeing's government operations.

K&E submission (EFTA00013811) is the firm's formal brief to Deputy AG arguing for dismissal of Epstein federal case. Document argues: (1) Epstein's conduct is state-level crime, not federal. (2) No precedent for federal prosecution under 18 USC 1591/2422(b)/2423(b) on similar facts. (3) Epstein didn't use internet/phone to induce minors. (4) Victims said they were told to say they were 18. (5) Travel to Palm Beach was 'merely to go home.' Document spans 50K+ characters with detailed statutory analysis, witness summaries, and 14+ Tab exhibits. This is the K&E 'scorched earth' strategy that led to the NPA.

Benczkowski Alfa Bank representation scope: At K&E, brought into Alfa Bank matter by partner Viet Dinh (then K&E partner, later Fox Corp CLO). Scope: (1) Hired/oversaw Stroz Friedberg computer forensics investigation of Alfa Bank servers examining Feb-March 2017 traffic. (2) Analyzed whether hackers created fake cyber trail suggesting Alfa Bank-Trump Organization server communications. (3) Advised Alfa Bank on potential defamation case against BuzzFeed over Steele dossier publication. Work ran March to early June 2017; nominated for AAG almost immediately after. Alfa Bank is Russia's largest private bank, controlled by oligarchs Mikhail Fridman, Petr Aven, and German Khan.

Alfa Bank had ZERO FARA registrations despite being Russia's largest private bank controlled by oligarchs Fridman/Aven/Khan who are known political actors. K&E's representation of Alfa Bank (via Benczkowski/Dinh) was not registered under FARA. Separately, Alfa Bank was an actual financial intermediary used by the Epstein operation for international wire transfers to Russia (at least 10 documents in LMSBAND with wire instructions to Alfa Bank Moscow, SWIFT: ALFARUMM). The dual function of Alfa Bank -- as both Benczkowski's K&E client AND as Epstein's Russian banking conduit -- was never publicly connected during the confirmation process.

Benczkowski complete career timeline: (1) 2002-2004: Staff Director/Senior Counsel, Office of Legal Policy. (2) 2006-2007: Chief of Staff, ATF. (3) 2007-2008: Principal Deputy AAG, Legislative Affairs (authored Nov 9, 2007 letter cited by K&E in Epstein defense). (4) 2008: Chief of Staff to Deputy AG Mark Filip (K&E alum who received Ken Starr's letter re Epstein NPA). (5) 2008-2009: Chief of Staff to AG Mukasey. (6) 2009-2010: Republican Staff Director, Senate Judiciary Committee. (7) 2010-2017: Partner, Kirkland & Ellis. (8) March-June 2017: Represented Alfa Bank at K&E. (9) June 2017: Nominated for AAG Criminal Division. (10) July 11, 2018: Confirmed 51-48. (11) July 2018-July 3, 2020: AAG Criminal Division. (12) Sept 1, 2020: Returned to K&E as partner. (13) Sept 2025: Joined Boeing as VP/Assistant General Counsel, Government Operations.