Looking forward to speaking later today. Early afternoon cg 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:
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
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 Head", maybe a list of names like prior AFC
Heads, Business Heads, COOs.
Speak later,
Wolfram
Wolfram Lange
Managing Director I Divisional Control Officer
Deutsche Bank Wealth Management
The Zig Zag Building, SW IE 6SQ, London, United Kingdom
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