EFTA Document EFTA01399051

Subject: RE: Initial thou hts [I] From: Michael Off Date: Mon, 15 Jul 2019 07:29:59 -0400 To: Kimberly Hart Classification: For internal use only Yes I just received message from Martina that she had an accident and cannot work today. Kind regards Michael Off fcid:80063086-E6B1-464A-83C1-C22D037DB24E@lanl Michael Off Divisional Control Office Deutsche Bank Wealth Management Deutsche Bank AG Taunusanlage 12, 60325 Frankfurt am Main, Germany Tel Mobile From: Kimberly Hart EFTA01399051 Sent: Montag, 15. Juli 2019 13:06 To: Wolfram Lange Cc: Martina Messing Subject: Re: Initial thoughts Michael - ; Michael Off e > 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 e > 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... EFTA01399052 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: 1) 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 Head", maybe a list of names like prior AFC Heads, Business Heads, COOs. EFTA01399053 Speak later, Wolfram Wolfram Lange Managing Director I Divisional Control Officer Deutsche Bank Wealth Management The Zi Za Buildin , SW1E 6SQ, London, United Kingdom Tel. Mobile Email EFTA01399054