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sd-10-EFTA01357345Dept. of JusticeOtherEFTA Document EFTA01357345
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Dept. of Justice
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sd-10-EFTA01357345
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Summary
Good Morning: As a part of the anti-money laundering monitoring program, the Actimize system is used to automatically identify transactions that meet certain high risk transaction patterns. When transactions occur which mimic those patterns, the activity must be researched to confirm that it is legitimate. In a small percentage of these cases, Compliance must contact the Wealth Advisor for additional information about the transaction(s) in order to conclude the research process. Your respon
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EFTA DisclosureText extracted via OCR from the original document. May contain errors from the scanning process.
Good Morning:
As a part of the anti-money laundering monitoring program, the Actimize system is used to automatically identify
transactions that meet certain high risk transaction patterns. When transactions occur which mimic those patterns, the
activity must be researched to confirm that it is legitimate.
In a small percentage of these cases, Compliance must contact the Wealth Advisor for additional information about the
transaction(s) in order to conclude the research process. Your response is required for the Bank to comply with federal
guidelines for concluding the research of these matters in a timely fashion. Your complete response must be received
within 7 business days.
To the best of your ability, please provide details regarding the item(s) below:
Incoming:
10/27/2016, $6,186,980.68, HSBC SECURITIES SERVICES (IRELAND) DAC at HSBC BANK USA, NATIONAL ASSOCIATION
1. Who is the ultimate originator of these funds (i.e. if this is investment income, please give the name of the
investment that the funds originate)?
Outgoing:
11/23/2016, $25,000,000.00, AP NARROWS HOLDING LP/BMO TRUSTEE at CDEC CLEARING ACCOUNT through BANK
OF AMERICA, N.A., NY
11/23/2016, $5,000,000.00, LOB 2011 LLC/BMO TRUSTEE at CDEC CLEARING ACCOUNT through BANK OF AMERICA,
N.A.. NY
1. What is the purpose of the Outgoing Transfer?
2. What is the relationship between Beneficiary and Client?
3. Please provide the source of wealth for these entities.
Thank you in advance for your prompt attention to this matter.
Best Regards/Mit freundlichen GriiRen.
PWM AML Compliance
Deutsche Bank
60 Wall St., 23 Floor
New York, NY 10005 - 2836
pwm.amIcompliance©db.com
Fax: 646-259-3255
PLEASE NOTE: YOU ARE BEING CONTACTED BECAUSE YOU ARE LISTED AS THE PRIMARY OFFICER FOR
THIS ACCOUNT ON GCIS. IF YOU ARE NOT THE CURRENT PRIMARY OFFICER, PLEASE LET ME KNOW
IMMEDIATELY, SO THAT I MAY FORWARD THIS EMAIL TO THE APPROPRIATE PARTY.
Do not forward this e-mail or any attachment directly to the client.
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0043830
CONFIDENTIAL
SDNY_GM_00190014
EFTA01357345
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