Subject: ACTION REQUIRED: Issue related to ACUs [I]
From: Armen Brash a>
Date: Tue, 13 Oct 2015 18:36:40 -0400
To: Paul Morris
Amanda Kirby
Classification: For internal use only
Paul and Amanda,
As you may know, per the AML Procedures manual, certain clients are excluded
from ACUs. An issue has been identified in dbforce where High Risk clients
are given an ACU Auto Exemption for Retail Banking, however, per Policy,
this exception does NOT apply to High Risk clients.
Unfortunately, the code in dbforce exempting high risk clients with only
deposit accounts under $250K from the ACU when it should not be—the code
will be fixed ASAP, but in the meanwhile, while the ACUs listed below don't
appear as overdue, they must be completed by year end.
Customer Name
Customer #
Relationship
Primary Officer
ACU Completed Date
Butterfly Trust
SOUTHERN FINANCIAL RELATIONSHIP
Paul Morris
EFTA01475244
The 2007 Jeffrey E. Epstein Insurance Trust #3
SOUTHERN FINANCIAL RELATIONSHIP
Paul Morris
New York Strategy Group, LLC
SOUTHERN FINANCIAL RELATIONSHIP
Paul Morris
Plan D, LLC
SOUTHERN FINANCIAL RELATIONSHIP
Paul Morris
HBRK Associates, Inc
SOUTHERN FINANCIAL RELATIONSHIP
Paul Morris
Hyperion Air, LLC
SOUTHERN FINANCIAL RELATIONSHIP
Paul Morris
EFTA01475245
JEGE, Inc
SOUTHERN FINANCIAL RELATIONSHIP
Paul Morris
Neptune, LLC
SOUTHERN FINANCIAL RELATIONSHIP
Paul Morris
SOUTHERN FINANCIAL RELATIONSHIP
Paul Morris
Zorro Development Corp.
SOUTHERN FINANCIAL RELATIONSHIP
Paul Morris
Gratitude America
EFTA01475246
SOUTHERN FINANCIAL RELATIONSHIP
Paul Morris
Please let me know if you have any questions and please let me know when
this has been completed.
Best,
Armen
Armen Brash
Director
Deutsche Asset & Wealth Management
345 Park Avenue, 10154-0004 New York, NY, USA
Tel. Fax
Mobile
Email
EFTA01475247