Illegal Activity
suspicious
Blackmail
none
Date
2018-08-24
Document Type
email
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:41
Summary
Vijay Sawant from Deutsche Bank is requesting clarification regarding Butterfly Trust's nature (personal vs. corporate) and noting that Richard Kahn was added as manager of Neptune LLC without being added as a Registered Person in the KYC case. The email is part of a periodic review of high-risk accounts and aims to ensure compliance with KYC/AML regulations.
Metadata
- Subject
- RE: 2018 Periodic Review of High Risked Accounts Butterfly Trust (GCIS#486426) and Neptune, LLC (GCIS#487264) under t e SOUTHERN FINANCIAL RELATIONSHIP
- Sender
- Vijay-A Sawant
- Recipients
- Stewart Oldfield, Richard Iarossi
- Document ID
- KYC Case#01790739
- Date
- 2018-08-24
Illegal Activity
- Severity
- suspicious
- Description
- The email discusses the review of high-risk accounts and discrepancies in KYC information, which could potentially indicate money laundering or other financial crimes. However, the email itself does not contain clear evidence of illegal activity.
- Content Type
- first_hand
Evidence:
- Review of high-risk accounts
- Discrepancies in KYC information
Relationships 3
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Neptune LLC | manager | Richard Kahn | Richard Kahn added as manager of Neptune LLC |
| Butterfly Trust | client | Deutsche Bank | Butterfly Trust is a client of Deutsche Bank |
| Neptune LLC | client | Deutsche Bank | Neptune LLC is a client of Deutsche Bank |
Notable Quotes 2
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 Case#01790739.
Kindly confirm if this is a Personal Trust and NOT Corporate Trust? After reviewing the trust agreement, we noticed that the UBO's seem not related to the grantor.
Red Flags 2
- Discrepancy in KYC information for Richard Kahn as manager of Neptune LLC.
- Unclear relationship between UBOs and grantor of Butterfly Trust.
Financial Information
Assets:
- High Risked Accounts
- Butterfly Trust
- Neptune, LLC
Public Knowledge
- Context
- Review of high-risk accounts and KYC discrepancies at Deutsche Bank could be of interest to media.
- Media Worthy
- Yes
Legal Compliance
- Richard Kahn was added as manager of Neptune LLC but not as an RP in the previously approved KYC Case#01790739.
- Need to determine if Butterfly Trust is a Personal Trust or Corporate Trust to determine if CDD form is required.
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowBusiness dealingsCommunications/correspondence
Organizations 5
Neptune LLCButterfly TrustDeutsche O8 Centre Private LimitedDeutsche Bank GroupSOUTHERN FINANCIAL RELATIONSHIP
Locations 3
MumbaiIndiaNirlon Knowledge Park, Western Express Highway Goregaon East, Mumbai 400063, India
Financial Entities 1
Deutsche Bank
Text Analysis
- Tone
- Professional
- Purpose
- To request confirmation and clarification regarding Butterfly Trust and Neptune LLC for KYC/AML compliance.
- Significance
- The email discusses the periodic review of high-risk accounts and highlights discrepancies in the KYC information for Neptune LLC and requests clarification on the nature of Butterfly Trust.
File Info
- File Name
- EFTA01378765.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:41:12.748111
- DOJ Source
- View on DOJ