EFTA01356833.pdf

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 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: I) 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 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042958 CONFIDENTIAL SONY GM_00189142 EFTA01356833