1) 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 DC0/B1/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 Head", maybe a list of names
like prior AFC Heads, Business Heads, COOs.
3) ...?
Speak later,
Wolfram
Wolfram Lange
Managing Director I Divisional Control Officer
Deutsche Bank Wealth Management
ndon, United Kingdom
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042455
CONFIDENTIAL SDNY GM_00188639
EFTA01356548