EFTA Document EFTA01399599

Subject: RE: Cases with ne ative media risk [C] From: Emily Craig Date: Mon, 15 Jul 2019 09:54:00 -0400 To: Kimberly Hart ‹ > Classification: Confidential Correct, no longer used. We have the Client Risk Rating Engine, negative media is a Special Risk Factor which is reviewed by AFC, and if the CRRE gives a M/L, AFC can override the client to High due to that special risk factor. Kind Regards, Emily Emily Craig Director Deutsche Bank Wealth Management Deutsche Bank Securities, Inc 1 South Street, Baltimore, MD 21202-3298 Tel: Mobile: WM Mercury on myDB From: Kimberly Hart Sent: Monday, Jul 15, 2019 9:53 AM To: Emily Craig Subject: RE: Cases with negative media risk [C] Classification: Confidential I pulled it from one of the risk calculator worksheets — looks like inputs to the risk calculation. Is it no longer used? « OLE Object: Picture (Device Independent Bitmap) » Kimberly Hart EFTA01399599 Managing Director I Divisional Control Officer Wealth Management Americas Deutsche Bank Trust Company Americas 345 Park Avenue, 14th floor, New York, NY 10154 Tel. Fax Mobile Email Securities offered through Deutsche Bank Securities Inc. From: Emily Craig Sent: Monday, July 15, 2019 9:51 AM To: Kimberly Hart ‹ > Subject: RE: Cases with negative media risk [C] Classification: Confidential Kim, Where is this rep risk chart used? I am not familiar with it? Kind Regards, Emily « OLE Object: Picture (Device Independent Bitmap) Emily Craig Director Deutsche Bank Wealth Management Deutsche Bank Securities, Inc 1 South Street, Baltimore, MD 21202-3298 Tel: Mobile: WM Mercury on myDB > > From: Kimberly Hart Sent: Monday, July 15, 2019 9:47 AM To: Emily Craig <a Thomas Klemm < › Subject: RE: Cases with negative media risk [C] EFTA01399600 Classification: Confidential I had a chance to brainstorm with Wolfram and Michael Off this morning — and their suggestions were very similar to those offered by Emily. Review CAF and Rep Risk decisions for WM Americas client onboardings Review HR clients where "Negative Media" contributed to the high risk rating. How do we review the risk calculations to determine which customers have a risk rating greater than "1" in any of the below Client Reputational Risk categories? « OLE Object: Picture (Device Independent Bitmap) » Review RDC alerts associated with clients/related parties and the rationales for clearance. Is there a database that contains the records of RDC clearances? « OLE Object: Picture (Device Independent Bitmap) » Kimberly Hart Managing Director I Divisional Control Officer Wealth Management Americas Deutsche Bank Trust Company Americas 345 Park Avenue, 14th floor, New York, NY 10154 Tel. Fax Mobile Email Securities offered through Deutsche Bank Securities Inc. From: Emily Craig Sent: Saturday, July 13, 2019 1:23 PM To: Thomas Klemm Cc: Kimberly Hart Subject: RE: Cases with negative media risk [C] Classification: Confidential RDC does a daily reverse check against all parties and alerts on negative media. FircoSoft just went live with a daily reverse check for negative media, and Berlin working through the backlog. EFTA01399601 On top of that, we want to do a query of any negative media KYC summary comments and try to see where we may have onboarded WITH negative media known? Attached is a view a query I asked Brian for a few weeks ago. The request I made to him was: « File: Negative Media - Emily Craig.xlsx » I need a report of all cases, since beginning of the year, that show a "yes" for negative media, in any of the sections on this topic and corresponding comments/case/client/risk details. Note from Brian: (Be a little careful with Column R. Excel allows a maximum row height of 409, which isn't enough to view all text for all rows. If you click the cell, you can view the entire text in the formula bar — the first 3,800 characters anyway — that's a limitation that I tried to get around, but can't find a way to do it.) This is the report we are using to try to determine which data sources provide the most relevant risk data with Barbara. We could expand this timeframe and do "Key Word" search? Other initial brainstorm ideas: Do a review of all CAF/Rep Risk meeting notes as negative media as you describe, known at time of a KYC, could have been escalated by AFC to require a CAF/Rep Risk? Review any CRRE result L/M where client ended up H risk rating (would be due to a Special Risk Factor, like Negative Media) Our biggest risk/unknowns will be remediation cases where all parties are not currently known/captured and not query-able/part of current reverse checks. Kind Regards, Emily Emily Craig Director Deutsche Bank Wealth Management Deutsche Bank Securities, Inc 1 South Street, Baltimore, MD 21202-3298 Tel: Mobile: WM Mercury on myDB EFTA01399602 Original Message From: Thomas Klemm Sent: Friday, July 12, 2019 9:54 PM To: Emily Craig Cc: Kimberly Hart Subject: Cases with Hi Emily, > negative media risk We need to come up by Tuesday with an approach to doublecheck our client files on a risk based approach as good as possible for any potential criminal background that would most likely result in termination of the relationship. Ask is to ensure that we don't have any ,epstein' type of client on our books. What do you think would be the best way to do this? I'm not aware that we have specific negative media flags in the system but I thought we had free text fields? Everything related to bribery, sex trafficking, etc. would need to be manually reviewed with utmost scrutiny on top of any potential RR activity. We also might want to start with the HR population. Any thoughts how to practically approach that? Thanks a lot and have a good weekend! EFTA01399603