EFTA Document EFTA01368706

Deutsche Bank Compliance VELOCITY INTRODUCTION The Velocity rule identifies activity that may be indicative of attempts to use bank accounts as 'pass- throughs" to facilitate layering of transactions and obscure the trail of funds. This rule will allow AML Compliance to identify situations where funds enter a PWM account and then exit the account within a shod timeframe. Since there are various ways (transaction types) that funds may enter and leave PWM accounts, this family of rules will