Case File
efta-01356833DOJ Data Set 10OtherEFTA01356833
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DOJ Data Set 10
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efta-01356833
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Does 2pm CET work for you (3pm Frankfurt/9am NY)? If yes, I
will send invite.
Kimberly Hart
Managing Director I Divisional Control Officer
Wealth Management Americas
Deutsche Bank Trust Company Americas
345 Park Avenue, New York, NY 10154
Tel.
Fax
Mobile
Email
Securities offered through Deutsche Bank Securities Inc
On Jul 15 2019 at 2:20 AM, Wolfram Lange
wrote:
Kim, Michael
Looking forward to speaking later today. Early
afternoon eg 2pm CET would work best.
Here a couple of thoughts - need refinement and
challenge...
Problem statement:
Find client cases where we rely on some prior
decision and do not question a `borderline' client
relationship - example Epstein where clearance was
given again and again despite negative media and
other alerts always referring back to Packard/Caruso
onboarding decision (even though both had long
since left DB).
Potential solutions:
I) Assuming that negative media hits and respective
clearances are stored: conduct a fuzzy logic search
through all clearance statements looking for phrases
such as "as per prior approval", " based on decision
by", "...". Any hits to be reviewed by
DCO/BI/AFC.
2) Search the KYC files for unusually senior sign
off parties for onboarding in AFC and the business -
come up with a way to electronically search for key
words, such as " exception referral", "regional AFC
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0042958
CONFIDENTIAL
SONY GM_00189142
EFTA01356833
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