Illegal Activity
suspicious
Blackmail
possible
Date
Unknown
Document Type
other
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:43
Summary
This document is a Deutsche Bank form outlining the due diligence and compliance procedures for onboarding new clients, specifically MIX LLC and Plan D. LLC. It highlights the various approvals and documentation required, particularly for clients with US connections, potential regulatory risks, or PEP status, and mentions the need to summarize any negative news associated with the client.
Metadata
- Subject
- Deutsche Bank Account Holder
- Sender
- —
- Recipients
- —
- Document ID
- 1177014
- Date
- —
Illegal Activity
- Severity
- suspicious
- Description
- The document itself does not contain clear evidence of illegal activity, but the references to PEPs, negative news, and offshore PICs raise suspicions and warrant further investigation.
- Content Type
- none
Blackmail Indicators
- Likelihood
- possible
- Description
- The document mentions 'negative news' and summarization of it, which could potentially be used for leverage. The PEP (Politically Exposed Person) determination also suggests a need for careful scrutiny, which could be related to potential vulnerabilities.
Relationships 3
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| MIX LLC | Account Holder | Plan D. LLC | Both are listed as account holders at Deutsche Bank. |
| Arrant Epelein | Sole Member | NES LLC | Arrant Epelein is the Sole Member of NES LLC. |
| Paul Metal | Member | Plan D LLC | Paul Metal is a member of Plan D LLC. |
Media & Journalist References
- PEP/negative media escalation Approval
Public Knowledge
- Context
- The document relates to internal banking procedures and client onboarding, which is generally not public knowledge. However, the involvement of PEPs and potential regulatory risks could make it of interest to the media.
- Media Worthy
- Yes
Legal Compliance
- ABR Approval required for US clients with indictments of US status
- AFC Regulatory Risk Approval (Pending nexus)
- AML Compliance & BRM Approval for US persons with an offshore PIC
- Cross Border Approval
- CRP Legislation Body Approval
- ExCo Approval
- FinCEN COO Rule Form
- German Bank Separation Act (GBSA) Questionnaire
- Group Suits/Insolvency Approval
- Industry Rep Risk Escalation
- MD Approval
- Normal/target market Approval
- PEP/negative media escalation Approval
- Venezuela Line of business Approval
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowLegal matters/litigationBusiness dealingsCompliance/regulatory
Organizations 5
Deutsche BankMIX LLCPlan D. LLCNES LLCFinCEN
Locations 4
NYCUS Vow IslandsEUGerman
Financial Entities 1
Deutsche Bank
Text Analysis
- Tone
- Formal
- Purpose
- To document information and approvals related to new client accounts at Deutsche Bank.
- Significance
- The document outlines the due diligence and compliance procedures required for onboarding new clients, particularly those with US connections or potential regulatory risks.
File Info
- File Name
- EFTA01298881.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:43:49.770582
- DOJ Source
- View on DOJ