Illegal Activity
suspicious
Blackmail
none
Date
2018-08-31
Document Type
email
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:43
Summary
This email discusses KYC compliance issues for Butterfly Trust and Neptune LLC, specifically regarding the relationship between the UBOs and the grantor of the Butterfly Trust, and the addition of Richard Kahn as a manager of Neptune LLC without being added as an RP in the previously approved KYC case. Vijay-A Sawant requests clarification from Stewart Oldfield to complete the KYC case and submit it to AML for approval.
Metadata
- Subject
- Re: 2018 Periodic Review of High Risked Accounts
- Sender
- Stewart Oldfield
- Recipients
- Vijay-A Sawant, Richard larossi, Mayur Rathod, Bradley Gillin
- Document ID
- KYC Case#01977698
- Date
- 2018-08-31
Illegal Activity
- Severity
- suspicious
- Description
- The email discusses potential issues with KYC compliance, specifically regarding the relationship between the UBOs and the grantor of the Butterfly Trust, and the addition of Richard Kahn as a manager of Neptune LLC without being added as an RP in the previously approved KYC case. These issues could potentially indicate money laundering or other financial crimes.
- Content Type
- first_hand
Relationships 5
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Stewart Oldfield | Employment | Deutsche Bank Trust Company Americas | Stewart Oldfield is a Director at Deutsche Bank Trust Company Americas |
| Vijay-A Sawant | Employment | Deutsche Bank | Vijay-A Sawant works at Deutsche Bank |
| Butterfly Trust | Financial | SOUTHERN FINANCIAL RELATIONSHIP | Butterfly Trust is under the SOUTHERN FINANCIAL RELATIONSHIP |
| Neptune, LLC | Financial | SOUTHERN FINANCIAL RELATIONSHIP | Neptune, LLC is under the SOUTHERN FINANCIAL RELATIONSHIP |
| Richard Kahn | Manager | Neptune LLC | Richard Kahn has been added as manager as per Operating Agreement |
Notable Quotes 2
Butterfly trust — 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.
Neptune LLC — 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.
Red Flags 2
- The UBOs of Butterfly Trust seem not related to the grantor, raising questions about the nature of the trust.
- Richard Kahn was added as a manager of Neptune LLC without being added as an RP in the previously approved KYC case.
Financial Information
Assets:
- Butterfly Trust
- Neptune, LLC
Legal Compliance
- KYC compliance for high-risk accounts
- CDD form requirement for Corporate Trusts
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowBusiness dealingsCommunications/correspondenceLegal matters/litigation
Organizations 7
Deutsche Bank Trust Company AmericasDeutsche Bank Wealth ManagementDeutsche Bank Securities Inc.Butterfly TrustNeptune, LLCSOUTHERN FINANCIAL RELATIONSHIPAML
Locations 3
Mumbai, IndiaNew York, NY345 Park Avenue, New York, NY 10154
Financial Entities 1
Deutsche Bank
Text Analysis
- Tone
- Professional
- Purpose
- To clarify KYC requirements for Butterfly Trust and Neptune LLC accounts.
- Significance
- The email discusses the KYC (Know Your Customer) process for high-risk accounts, specifically Butterfly Trust and Neptune LLC, and raises questions about the relationship between the UBOs and the grantor of the Butterfly Trust, as well as the addition of Richard Kahn as a manager of Neptune LLC.
File Info
- File Name
- EFTA01387413.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:43:10.735499
- DOJ Source
- View on DOJ