EFTA Document EFTA01370241

Deutsche Bank Compliance LARGE CASH DEPOSITS INTRODUCTION The Large Cash Deposits rule specifically targets cash deposits and aggregate cash deposit activity for a specific customer and creates a case when the aggregate amount of cash deposits exceeds $27,000 (10% tolerance with max. total CTR amount of $30,000) over a one month period. Individual transactions must be at least $9,000. This rule is designed to be complementary to the Suspicious Cash Transactions rule because it identifies accounts where there has been a pattern of cash deposit activity throughout a one month period. Only three alerts have been generated since January 1, 2011. ANALYTICAL PROCESS A review of all cash deposits from January 1, 2011 to December 31, 2011 was conducted. Over the course of a year, a total of 244 cash deposits received. Only 2 deposits were for amounts greater than $10,000. and 17 of the 244 cash deposits were for amounts between $7,000 and $10,000. It appears that the same customers tend to have recurring cash activity since the larger cash deposits ($7,000 or more) are only linked to 5 customers. RECOMMENDATION Recommend adjusting alert parameters by lowering the individual transaction amount from 59,000 to $7,000 and increasing the maximum aggregate amount from $30,000 to $150,000. As previously noted, a quarterly cash transaction review is conducted every quarter to evaluate Branch cash reports along with Prime's cash transaction history including large cash deposits. httP:ied b.comil 19 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0062904 CONFIDENTIAL SDNY_GM_00209088 EFTA01370241