EFTA Document EFTA01399467

Subject: Re: Initial thou hts From: Wolfram Lange Date: Mon, 15 Jul 2019 07:48:04 -0400 To: Kimberly Hart Cc: Michael Off Martina Messing It is actually 2pm Frankfurt time, ie CET = Frankfurt Wolfram Lange Managing Director I Divisional Control Officer Deutsche Bank Wealth Management The Zi Za Buildin , SW1E 6SQ, London, United Kingdom Tel. Mobile + Email On 15 Jul 2019, at 12:06, Kimberly Hart a wrote: Michael - 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 EFTA01399467 On Jul 15, 2019, at 2:20 AM, Wolfram Lange a= > 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... 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. Speak later, Wolfram EFTA01399468 Wolfram Lange Managing Director I Divisional Control Officer Deutsche Bank Wealth Management The Zig Zag Building, SW1E 6SQ, London, United Kingdom Tel. Mobile Email EFTA01399469