Illegal Activity
suspicious
Blackmail
none
Date
2018-08-31
Document Type
email
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:42
Summary
Vijay Sawant from Deutsche Bank is requesting clarification on KYC information for Butterfly Trust and Neptune LLC, specifically regarding the nature of the trust and the addition of Richard Kahn as a manager. The email highlights potential compliance issues and the need for further investigation before submitting the case to AML for approval.
Metadata
- Subject
- RE: 2018 Periodic Review of High Risked Accoun and Neptune, LLC (GCIS#487264) under the SOUTHERN FINANCIAL RELATIONSHIP (II
- Sender
- Vijay-A Sawa
- Recipients
- Stewart Oldfield, Richard larossi
- Document ID
- GCIS#487264, GCIS#486426
- Date
- 2018-08-31
Illegal Activity
- Severity
- suspicious
- Description
- The email raises concerns about KYC compliance and potential discrepancies in the information provided for Butterfly Trust and Neptune LLC, which could be indicative of money laundering or other financial crimes. The addition of Richard Kahn as a manager without prior KYC approval is also suspicious.
- Content Type
- first_hand
Relationships 4
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Vijay-A Sawant | email correspondence | Stewart Oldfield | Vijay Sawant is requesting information from Stewart Oldfield and Richard larossi regarding KYC cases for Butterfly Trust and Neptune LLC. |
| Butterfly Trust | client | Deutsche Bank | Butterfly Trust is a client of Deutsche Bank, undergoing KYC review. |
| Neptune LLC | client | Deutsche Bank | Neptune LLC is a client of Deutsche Bank, undergoing KYC review. |
| Richard Kahn | manager | Neptune LLC | Richard Kahn has been added as manager to Neptune LLC. |
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. The reason for this request is to evaluate whether we require CDD form for this account or not. NOTE: we require CDD form ONLY in case of Corporate Trusts.
Neptune LLC — Please note that Richard Kahn has been added as mans er as er Operating Agreement even though he was NOT added as an RP in the previously approved KYC Case
Red Flags 2
- Discrepancy between UBOs and grantor in Butterfly Trust.
- Addition of Richard Kahn as manager of Neptune LLC without prior KYC approval.
Legal Compliance
- KYC compliance issues with Butterfly Trust and Neptune LLC.
- Need to determine if CDD (Customer Due Diligence) form is required for Butterfly Trust based on whether it's a personal or corporate trust.
- Richard Kahn's addition as manager of Neptune LLC requires verification and update to KYC documentation.
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowLegal matters/litigationBusiness dealingsCommunications/correspondence
Organizations 6
Deutsche CM Centre Private limitedDeutsche Bank GroupWealth ManagementButterfly TrustNeptune LLCAML
Locations 3
Mumbai, IndiaNirlon Knowledge Park, Western Express HighwayDB Centre Mumbai
Financial Entities 1
Deutsche Bank
Text Analysis
- Tone
- Professional
- Purpose
- To request clarification and confirmation regarding KYC (Know Your Customer) information for Butterfly Trust and Neptune LLC to complete the case and submit to AML for approval.
- Significance
- The email highlights potential issues with the KYC process for Butterfly Trust and Neptune LLC, specifically regarding the nature of the trust (personal vs. corporate) and the addition of Richard Kahn as a manager of Neptune LLC.
File Info
- File Name
- EFTA01387951.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:42:30.867642
- DOJ Source
- View on DOJ