Illegal Activity
suspicious
Blackmail
none
Date
2017-04, 2017-07, 2017-09, 2017-10
Document Type
other
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:41
Summary
Janice Franklin from Deutsche Bank Americas is documenting discrepancies found in the MRC deck statistics related to KYC and NCA risk assessments for April, July, September, and October 2017. The discrepancies involve the number of high, moderate, and low-risk clients reported versus the actual numbers found in the NCA reports, raising concerns about the accuracy of risk assessment reporting.
Metadata
- Subject
- Review of MRC deck statistics
- Sender
- Janice P. Franklin
- Recipients
- —
- Document ID
- DB-SDNY-0062675, SDNY_GM_00208859
- Date
- 2017-04, 2017-07, 2017-09, 2017-10
Illegal Activity
- Severity
- suspicious
- Description
- The document highlights discrepancies in risk assessment reporting, which could potentially indicate issues with AML compliance. However, it does not explicitly detail any illegal activities being committed.
- Content Type
- first_hand
Evidence:
- Discrepancies in KYC and NCA risk assessment reporting could indicate potential AML compliance issues.
Relationships 2
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Janice P. Franklin | Employment | Deutsche Bank Americas | Janice P. Franklin is Vice President I AML Compliance Officer at Deutsche Bank Americas |
| WM AFC | Information sharing | MI team | WM AFC provides metrics to the MI team |
Notable Quotes 2
GA reviewed the statistics provided in the MRC deck (page 48) and noted: 0 permanent exceptions granted for high-risk KYCs; and 4 permanent exceptions granted on low and moderate KYCs.
For Private Bank. MRC slide 146 of the MRC deck reflects incorrect statistics.
Red Flags 1
- Inconsistencies in risk assessment reporting between different sources within Deutsche Bank.
Legal Compliance
- Discrepancies in KYC and NCA risk assessment reporting
- Potential issues with regulatory compliance
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowLegal matters/litigationCompliance/correspondence
People 1
Organizations 5
MRCDeutsche Bank AmericasPershingAccountsWithAmlRiskDesignationWM AFCMI team
Locations 2
New York, NY, USA60 Wall Street
Financial Entities 2
Private BankBrokerage
Text Analysis
- Tone
- Professional
- Purpose
- To document discrepancies found in the MRC deck statistics related to KYC and NCA risk assessments.
- Significance
- The document highlights potential issues with the accuracy of risk assessment reporting within Deutsche Bank's Private Bank and Brokerage divisions, which could have implications for regulatory compliance.
File Info
- File Name
- EFTA01370078.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:41:38.546297
- DOJ Source
- View on DOJ