EFTA01413542.pdf
dataset_10 PDF 95.1 KB • Feb 4, 2026 • 3 pages
Subject: RE: WM Data Anal sis for AML Risk Assessment [I]
From: Cherie Quigley
Date: Tue, 10 Mar 2015 16:02:37 -0400
To: Sharon Donaghey
Classification: For internal use only
Hi Sharon
Here are the spreadsheets.
Cherie
From: Sharon Donaghey
Sent: Thursday, March 05, 2015 3:18 PM
To: Cherie Quigley; Ying-A Wang
Cc: Wayne Salit
Subject: WM Data Analysis for AML Risk Assessment [I]
Classification: For internal use only
Hi Cherie and Ying,
I believe that Wayne spoke to you about gathering some metrics for the
products in the WM Investment Advisory Business so that we can complete the
AML Risk Assessment for 2014, which included data for 2012 and 2013. These
are the products that were indicated as applicable in the Spring of 2014:
Check deposits
Free delivery/receipt of securities
Internal Transfers
Investment Advisory
Wire Transactions
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Attached is a worksheet that includes the tables for the metrics that we
want to capture, i.e. the number of accounts, transaction volume and the
total transaction value by client risk rating and by country risk. If
possible, please also provide the metrics by client's high risk industry
status, but not if this will be more time consuming.
Data was collected last year and is available on the Risk Assessment
Sharepoint site. (You may have other options for pulling the data. If
that's the case, in order to be consistent with the other divisions, please
provide metrics for 2012 and 2013.) Here's the link to the site:
https://sharepoint.us.intranet.db.com/site2510/-
Fall%2020149620AML9620Risk%20Assmt/Forms/AllItems.aspx?-
RootFolder=962Fsite2510%2FFall96202014%20AML%20Risk%20Assmt%2FAWM962FData%20Ana-
lysis9620n%200ther&FolderCTID=Ox0120009280F9074D5AA142AC7BCAB4D1559F5D&View={-
7F9F3F7D-1490-40AE-BF00-4341EF424A5C}
Clarissa used this data to generate metrics for last year's assessment, but
it's not possible to get the metrics we need for this iteration of the
assessment: data needed to generate the metrics by client and country risk
needs to be mapped against the client data. If you have a few minutes,
I'll further explain the challenge that I had with getting the metrics
needed — it would be easier to show you in the worksheet.
Regards,
Sharon
Director, Financial Crimes Risk Assessments
Deutsche Bank Americas
60 Wall Street, 37th floor
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