EFTA Document EFTA01404972

Subject: Revised CLEARED Richard From: PWMUS AMLKYC Date: Fri, 01 Nov 2013 10:53:59 To: Amanda Kirby Cc: Jacqueline Lightbod PWMUS AMLKYC Janice Franklin < D Kahn Classification: For internal use only Hi Amanda - alert [I) This is a revision to the below clearance for Mr. Kahn - after further review it appears the below alert dated 9/3/2013 is a false positive. AML Compliance has reviewed an email dated 10/31/2013 that the business received from Mr. Kahn attesting that he has not been bared from NYSA Arca and that he is not the same individual as the alerted party. According to that email, our Mr. Kahn has been working at his company, HBRK Associates Inc for the past 3 years. The alert involves a Richard Kahn who was a limited partner of PennMont Securities, a former broker dealer, NASDAQ OMX PHLX and NYSE Arca member. On February 26, 2013 PennMont was banned from NYSE Arca membership due to various accounting, record keeping, and supervisory control deficiencies. AML Compliance finds these statements made by our Mr. Kahn reasonable evidence, and clears this alert as a false positive. Please see the email chain attached to this KYC, thanks! Best, Michael (Embedded image moved to file: pic02612.gif) Michael Vila Team Manager I AML Compliance Deutsche Bank Securities Inc. Asset a Wealth Management 5022 Gate Parkwa Suite 400, 32256 Jacksonville, USA Tel. (Embedded image moved to file: pic09754.gif) From: Amanda Kirby/ To: PWMUS AMLKYC/ Andrea Klingenberg/ Cc: Urvashi Lavania/ PWM BIS-Research/ Paul Morris; Date: 09/04/2013 11:09 AM Subject: Re: Richard D Kahn rdc alert [I) Classification: For internal use only EFTA01404972 Hi, The below RDC in question. account for a pose any risk alerts do pertain to our client. Richard D Kahn is the person However, he will not be a client of the bank. We are opening an trust, for which he is a trustee. It does not seem that he would (reputational or otherwise) to the bank. Please approve (See attached file: Richard D Kahn rdc alert.pdf) Richard D Kahn rdc alert_l.pdf) From: To: Cc: Date: Subject: PWM BIS-Research/ Amanda Kirby/ PWMUS AMLKYC/ 09/03/2013 04:32 PM Richard D Kahn rdc alert [II (See attached file: Classification: For internal use only Hello, Attached is an alert for the party mentioned above. Please note that clearance from compliance is required prior to KYC approval. Please follow the instructions below: Forward explanation of whether the alert pertains to your client directly to compliance. Receive confirmation from compliance that alert can be removed from the queue. Include copies of all responses along with your KYC. (attachment "Richard D Kahn rdc alert.pdf" deleted by Amanda Kirby/ (attachment "Richard D Kahn rdc alert_l.pdf" deleted by Amanda Kirby/ J Regards Urvashi EFTA01404973