EFTA Document EFTA01299321

Current Classification: (click here for help) Internal Revised_CLEARED_Richard D Kahn rdc alert [I] PWM US AMLKYC t Amanda Kirby Michael Vila Jacqueline Lightbody, PVVMUS AMLKYC, Janice Franklin 2 attachments Richard D Kahn rdc alert_1.pdf Richard D Kahn rdc alert.pdf Classification: For internal use only Hi Amanda - 11/011201310:54 AM This is a revision to the below clearance for Mr. Kahn - after further review it appears the below alert dated 9/3/2013 is a false positive. AML Compliance has reviewed an email dated 10/31/2013 that the business received from Mr. Kahn attesting that he has not been bared from NYSA Arca and that he is not the same individual as the alerted party. According to that email, our Mr. Kahn has been working at his company, HBRK Associates Inc for the past 3 years. The alert involves a Richard Kahn who was a limited partner of PennMont Securities, a former broker dealer, NASDAQ OMX PHLX and NYSE Arca member. On February 26, 2013 PennMont was banned from NYSE Arca membership due to various accounting, record keeping, and supervisory control deficiencies. AML Compliance finds these statements made by our Mr. Kahn reasonable evidence, and clears this alert as a false positive. Please see the email chain attached to this KYC, thanks! Best, Michael a Michael Vila Team Manager I AA4l. Compliance Deutsche Bank Securities Inc. Asset & Wealth Management 5022 Gate Parkway. Suite 400, 32256 Jacksonville. USA Tel. +1(904)527.6152 Email inichaelmiatroch.com Raclin..:ftr ?upon. Amanda Kirby—09/04/2013 11:09:44 AM—Classification: For internal use only Hi, The below RDC alerts do pertain to our client. Richard D SDNY_GM_00065230 CONFIDENTIAL - PURSUANT TO FED. R.CON(F IDENTIAL DB-SDNY-0028055 EFTA_00 I 75730 EFTA01299321 From: Amanda Kirby/db/dbcom To: PWMUS AMLICYC/0latdboorn@DBAMERICAS, Andrea Klingenberg/dbedbcom@DBAMERICAS, Cc: Unmshi Lavanialdb/dbcom@DBAPAC, PWM BIS-Researchidb/dbcomi@DBAPAC. Paul Maristdbrdbcom@DBAMERICAS Dom: 09O4/2013 11.09 AM Subject Re: Richard D Kahn rdc alert Ill Classification: For internal use only Hi, The below RDC alerts do pertain to our client. Richard D Kahn is the person in question. However, he will not be a client of the bank. We are opening an account for a trust, for which he is a trustee. It does not seem that he would pose any risk (reputational or otherwise) to the bank. Please approve (See attached file: Richard I) Kahn rdc alertpdfi (See attached file: Richard I) Kahn rdc alert 1.fxlI) PWM BIS-Research--09/03/2013 04:32:05 PM—Classification: For internal use only Hello, Attached is an alert for the party mentioned above. PI From: To: Cc: Dale: Subject: PWM BIS-ResearelVdbldbcom@DBAPAC Amanda Kirby/db/dbcom@D6AMERICAS, PWMUS AMLKYC/dlaidbcom©DBAmericas 09:03/2013 04:32 PM Richard D Kahn rdc alert Ill Classification: For internal use only Hello, Attached is an alert for the party mentioned above. Please note that clearance from compliance is required prior to KYC approval. Please follow the instructions below: Forward explanation of whether the alert pertains to your client directly to compliance. Receive confirmation from compliance that alert can be removed from the queue. Include copies of all responses along with your KYC. [attachment "Richard D Kahn rdc alert.pdf' deleted by Amanda Kirby/db/dbcomi [attachment "Richard 0 SDNY_GM_00065231 CONFIDENTIAL - PURSUANT TO FED. R.ctON(F IDENTIAL DB-SDNY-0028056 EFTA_00 I 75731 EFTA01299322 Kahn rdc alert_1.pdf' deleted by Amanda Kirby/db/dIxom] Regards Urvashi SDNY_GM_00065232 CONFIDENTIAL - PURSUANT TO FED. R.CON(F IDENTIAL DB-SDNY-0028057 EFTA_00 175732 EFTA01299323