EFTA Document EFTA01421789

Current Classification: (click here for help) Internal Revised_CLEARED_Richard D Kahn rdc alert (I] PWMUS AMLKYC to: Amanda Kirby Sent by: Michael Vila Cc: 2 attachments Richard D Kahn rdc alert_l.pdf Jacqueline Lightbody, PWMUS AMLKYC, Janice Franklin 11/01/2013 10:54 AM Richard D Kahn rdc alert.pdf Classification: For internal use only Hi Amanda - This is a revision to the below clearance for Mr. Kahn - after further review it appears the below a lert 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 n of 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 Michael Vila Team Manager I AML Compliance Deutsche Bank Securities Inc. Asset d Wealth Management 5022 Gate Parkwa Suite 400, 32256 Jacksonville, USA Tel. Email Amanda Kirby---09/04/2013 11:09:44 AM---Classification: For internal use only Hi, The below RDC alerts do pertain to our client. Richard D EFTA01421789 From: Amanda Kirby/db/dbcom To: Cc: Date: PWMUS AMLKYC/db/dbcom@DBAMERICAS, Andrea Klingenberg/db/dbcom@DBAMERICAS, Urvashi Lavania/db/dbcom@DBAPAC, PWM BIS-Research/db/dbcom@DBAPAC, Paul Morris/db/dbcom@DBAMERICAS 09/04/2013 11:09 AM Subject: Re: Richard D Kahn rdc alert (I] Classification: For internal use only Hi, The below RDC alerts do pertain to our client. Richard D Kahn is the person in question. However, he will not be a client of the bank. We are opening an account for a trust, for which he is a trustee. It does not seem that he would pose any risk (reputational or otherwise) to the bank. Please approve (See attached file: Richard D Kahn rdc alert.pdf) (See attached file: Richard D Kahn rdc alert_l.pdf) PWM BIS-Research---09/03/2013 04:32:05 PM---Classification: For internal use only Hello, Attached is an alert for the party mentioned above. P1 From: To: Cc: Date: Subject: PWM BIS-Research/db/dbcom@DBAPAC Amanda Kirby/db/dbcom@DBAMERICAS, PWMUS AMLKYC/db/dbcom@DBAmericas 09/03/2013 04:32 PM Richard D Kahn rdc alert (I] 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/db/dbcom] (attachment •Richard D EFTA01421790 Kahn rdc alert_l.pdf" deleted by Amanda Kirby/db/dbcom] Regards Urvashi EFTA01421791