Illegal Activity
suspicious
Blackmail
none
Date
2018-08-24
Document Type
email
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:43
Summary
Vijay Sawant is requesting clarification on the Butterfly Trust's UBOs and highlighting that Richard Kahn was added as a manager of Neptune LLC without prior KYC approval. The email pertains to the 2018 Periodic Review of High Risked Accounts and seeks to address potential compliance issues.
Metadata
- Subject
- RE: 2018 Periodic Review of High Risked Accounts
- Sender
- Vijay-A Sawant
- Recipients
- Stewart Oldfield, Richard larossi, Bradley Gitlin
- Document ID
- Caseit01790739
- Date
- 2018-08-24
Illegal Activity
- Severity
- suspicious
- Description
- The email discusses potential compliance issues related to KYC and UBO identification, which could be indicative of attempts to circumvent regulations, but does not explicitly describe illegal activity.
- Content Type
- first_hand
Relationships 4
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Vijay-A Sawant | email correspondence | Stewart Oldfield | Vijay Sawant is sending an email to Stewart Oldfield regarding the 2018 Periodic Review of High Risked Accounts. |
| Vijay-A Sawant | email correspondence | Richard larossi | Vijay Sawant is sending an email to Richard larossi regarding the 2018 Periodic Review of High Risked Accounts. |
| Vijay-A Sawant | email correspondence | Bradley Gitlin | Vijay Sawant is sending an email to Bradley Gitlin regarding the 2018 Periodic Review of High Risked Accounts. |
| Richard Kahn | manager | Neptune LLC | Richard Kahn has been added as manager of Neptune LLC. |
Notable Quotes 2
"After reviewing the trust agreement, we noticed that the UBO's seem not related to the grantor. The reason for this request is to evaluate whether we require CDD form for this account or not."
"Please note that Richard Kahn has been added as manager as per Operating Agreement even though he was NOT added as an RP in the previously approved KYC Caseit01790739."
Red Flags 2
- Discrepancy between UBOs and grantor for Butterfly Trust.
- Addition of Richard Kahn as manager of Neptune LLC without prior KYC approval.
Financial Information
Assets:
- High Risked Accounts
- Butterfly Trust
- Neptune, LLC
Legal Compliance
- Potential compliance issues related to the identification of Ultimate Beneficial Owners (UBOs) for Butterfly Trust.
- Richard Kahn has been added as manager of Neptune LLC without prior KYC approval.
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowBusiness dealingsCommunications/correspondenceLegal matters/litigation
Organizations 5
Butterfly TrustNeptune, LLCDeutsche CIB Centre Private LimitedDeutsche Bank GroupWealth Management
Locations 3
MumbaiIndiaDB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway Gore on East, Mumbai - 400063, India
Financial Entities 1
Deutsche Bank
Text Analysis
- Tone
- Professional
- Purpose
- To request confirmation and clarification regarding high-risk accounts under review.
- Significance
- The email highlights potential compliance issues related to the identification of Ultimate Beneficial Owners (UBOs) and the addition of a manager to Neptune LLC without prior KYC approval.
File Info
- File Name
- EFTA01375190.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:43:52.330374
- DOJ Source
- View on DOJ