Illegal Activity
suspicious
Blackmail
none
Date
2018-05-22
Document Type
email_chain
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:41
Summary
This email chain discusses an escalation regarding Southern Financial LLC's product extension request, highlighting issues with UK adoption and missing GB review dates. The team investigates the cause, identifies potential fixes, and works towards resolving the issue while ensuring compliance with AML/KYC procedures.
Metadata
- Subject
- RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I]
- Sender
- Nicholas Hislop
- Recipients
- Kareen Johnson, Simon Nall, Martin Zeman, Daniel-A Klyashtorny, Nina Tona, Xavier Avila, Davide-A Sferrazza, AMLUK Reviews, Devshiji Odedra, Ian Salters, Ricky-x Patel, Jesse-J Cruz, Zack Bunimovich, Jonathan Whittle, James Gladwin
- Document ID
- ONB-1135648 / LKYCGB-160049
- Date
- 2018-05-22
Illegal Activity
- Severity
- suspicious
- Description
- Potential AML/KYC compliance issues related to booking products without proper adoption and missing review dates.
- Content Type
- first_hand
Relationships 4
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Kareen Johnson | business | dbCLIENT merger team | Kareen Johnson will query the status/success of the KCP merge from dbCLIENT to dbCAR. |
| Nina Tona | business | James Gladwin | Nina Tona will provide James Gladwin with the list of KCP clients so that he can conduct a sanity sample check. |
| James Gladwin | business | Global CDS teams | James Gladwin liaised with Global CDS teams to identify key barriers and approve the Extension request. |
| Southern Financial LLC | business | Deutsche Bank | Southern Financial LLC is a client of Deutsche Bank. |
Notable Quotes 2
The concern is not because of the risk level and escalation, but the fact there was no previous GB review when products have been added since 2014.
Post investigation identified UK products had been booked WITHOUT a UK adoption — a never seen before scenario
Red Flags 2
- UK products had been booked WITHOUT a UK adoption.
- Missing GB review date when products have been added since 2014.
Financial Information
Amounts:100M
Assets:
- CDX IG payer spreads
- equities
- fixed income portfolio
Transactions:
- Southern Financial LLC looking to buy CDX IG payer spreads as a hedge for their overall equities and fixed income portfolio.
Legal Compliance
- Issue where in dbCAR this relationship did not reflect an old GB review date.
- UK products had been booked WITHOUT a UK adoption.
- The LRD for the US is 2016 and does not appear to be in the Remediation pipeline.
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowBusiness dealingsCommunications/correspondenceLegal matters/litigation
People 16
Organizations 11
Southern Financial LLCDeutsche BankDBAGDBOI Global Services (UK) LimitedDBSIII AGDBUSA Core Corp.AMLUK ReviewsAFC Business AdvisoryAnti-Financial CrimeGlobal CDS teams
Locations 7
LondonUKJacksonvilleBirminghamUnited KingdomUSAUS
Financial Entities 1
Southern Financial LLC
Text Analysis
- Tone
- Professional
- Purpose
- The purpose of this email chain is to resolve an issue with the extension request for Southern Financial LLC and to understand the cause of the issue for future requests.
- Significance
- This document highlights the complexities of cross-jurisdictional adoptions and the importance of proper KYC and AML procedures.
File Info
- File Name
- EFTA01400073.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:41:26.716161
- DOJ Source
- View on DOJ