Illegal Activity
suspicious
Blackmail
none
Date
2016-10-27
Document Type
email
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:41
Summary
This email from Deutsche Bank's PWM AML Compliance requests information from a Wealth Advisor regarding large incoming and outgoing transactions that triggered the anti-money laundering monitoring system. The email seeks details about the origin and purpose of the funds, as well as the relationship between the involved parties, to ensure compliance with federal guidelines.
Metadata
- Subject
- Anti-Money Laundering Monitoring Program - Request for Information
- Sender
- PWM AML Compliance
- Recipients
- —
- Document ID
- DB-SDNY-0048552
- Date
- 2016-10-27
Illegal Activity
- Severity
- suspicious
- Description
- The document describes transactions flagged by an anti-money laundering system, raising suspicion of potential illegal activity. The use of multiple entities and trustees could be an attempt to obscure the ultimate beneficiary of the funds.
- Categories
- Money laundering indicators
- Content Type
- first_hand
Evidence:
- Large, unexplained transactions flagged by AML monitoring system.
- Use of multiple entities and trustees for outgoing transfers, potentially obscuring the ultimate beneficiary.
Relationships 3
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| AP NARROWS HOLDING LP | Trustee | BMO TRUSTEE | BMO Trustee acts as trustee for AP NARROWS HOLDING LP |
| LOB 2011 LLC | Trustee | BMO TRUSTEE | BMO Trustee acts as trustee for LOB 2011 LLC |
| CDEC CLEARING ACCOUNT | Bank | BANK OF AMERICA, N.A. | CDEC CLEARING ACCOUNT is held through BANK OF AMERICA, N.A. |
Notable Quotes 2
As a part of the anti-money laundering monitoring program, the Actimize system is used to automatically identify transactions that meet certain high risk transaction patterns.
Your response is required for the Bank to comply with federal guidelines for concluding the research of these matters in a timely fashion.
Red Flags 2
- Large sum transactions ($6,186,980.68, $25,000,000.00, $5,000,000.00) triggering AML monitoring.
- Use of multiple entities (AP NARROWS HOLDING LP, LOB 2011 LLC) and trustees (BMO TRUSTEE) for outgoing transfers.
Financial Information
Amounts:$6,186,980.68$25,000,000.00$5,000,000.00
Transactions:
- Incoming: 10/27/2016, $6,186,980.68, HSBC SECURITIES SERVICES (IRELAND) DAC at HSBC BANK USA, NATIONAL ASSOCIATION
- Outgoing: 11/23/2016, $25,000,000.00, AP NARROWS HOLDING LP/BMO TRUSTEE at CDEC CLEARING ACCOUNT through BANK OF AMERICA, N.A., NY
- Outgoing: 11/23/2016, $5,000,000.00, LOB 2011 LLC/BMO TRUSTEE at CDEC CLEARING ACCOUNT through BANK OF AMERICA, N.A.. NY
Public Knowledge
- Context
- This document is part of a larger investigation into financial transactions and potential money laundering activities. The details of the transactions and the entities involved could be of interest to the media.
- Media Worthy
- Yes
Legal Compliance
- Potential anti-money laundering concerns due to high-risk transaction patterns identified by the Actimize system.
- Need to comply with federal guidelines for concluding the research of these matters in a timely fashion.
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowLegal matters/litigationCommunications/correspondenceAllegations/complaints
Organizations 9
ActimizeHSBC SECURITIES SERVICES (IRELAND) DACHSBC BANK USA, NATIONAL ASSOCIATIONAP NARROWS HOLDING LPBMO TRUSTEECDEC CLEARING ACCOUNTBANK OF AMERICA, N.A.LOB 2011 LLCDeutsche Bank
Locations 4
IrelandUSANew York60 Wall St., 23 Floor, New York. NY 10005 - 2836
Financial Entities 4
HSBC BANK USA, NATIONAL ASSOCIATIONBANK OF AMERICA, N.A.Deutsche BankBMO TRUSTEE
Text Analysis
- Tone
- Professional
- Purpose
- To request information about specific incoming and outgoing transactions as part of an anti-money laundering monitoring program.
- Significance
- The document highlights the bank's efforts to comply with federal guidelines for anti-money laundering and the need for Wealth Advisors to provide information about high-risk transactions.
File Info
- File Name
- EFTA01360294.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:41:01.214500
- DOJ Source
- View on DOJ