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EFTA01299283.pdf

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Ei Current Classification: (dick here for help) Internal
Revised_CLEARED_Richard D Kahn rdc alert [I]
PWMUS AMLKYC to Amanda Kirby 11/011201310:54 AM
Sent by: Michael Vila
Cc: Jacqueline Lightbody, PWMUS AMLKYC, Janice Franklin
2 attachments
Richard D Kahn rdc alert_l pdf Richard D Kahn rdc alertpdf
Classification: For internal use only
Hi Amanda -
This is a revision to the below clearance for Mr. Kahn - after further review it appears the below alert
dated 9/3/2013 is a false positive. AML Compliance has reviewed an email dated 10/31/2013 that the
business received from Mr. Kahn attesting that he has not been bared from NYSA Arca and that he is not
the same individual as the alerted party. According to that email, our Mr. Kahn has been working at his
company, HBRK Associates Inc for the past 3 years. The alert involves a Richard Kahn who was a
limited partner of PennMont Securities, a former broker dealer, NASDAQ OMX PHLX and NYSE Arca
member. On February 26, 2013 PennMont was banned from NYSE Arca membership due to various
accounting, record keeping, and supervisory control deficiencies. AML Compliance finds these
statements made by our Mr. Kahn reasonable evidence, and clears this alert as a false positive.
Please see the email chain attached to this KYC, thanks!
Best, Michael
Michael Vila
Team Manager I AML Compliance
Deutsche Bank Securities Inc.
Asset & Wealth Management
5022 Gate Pa Suite 400. 32256 Jacksonville. USA
Tel
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Amanda Kirby--09/04/2013 11:09:44 AM--Classification: For internal use only Hi. The below RDC
alerts do pertain to our client. Richard D
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EFTA01299283

From: Amanda Kirby/ddd0com
To:
Cc.
Date 09/04/2013 11:09 AM
Subject. Re: Richard D Kahn rdc art
Ill
Classification: For internal use only
Hi,
The below RDC alerts do pertain to our client. Richard D Kahn is the person in question. However, he
will not be a client of the bank. We are opening an account for a trust, for which he is a trustee. It does
not seem that he would pose any risk (reputational or otherwise) to the bank. Please approve
(cue attachedf ile: Richard D Kahn rdc alertiodfi (See attachedf ile: Richard D Kahn rdc
alert I.pdfi
PWM BIS-Research---09/03/2013 04:32:05 PM—Classification: For internal use only Hello, Attached is
an alert for the party mentioned above. PI
From:
To:
Cc:
Dale: 09/01/2013 04:32 PM
Subject: Richard D Kahn rdc alert
Iq
Classification: For internal use only
Hello,
Attached is an alert for the party mentioned above. Please note that clearance from compliance is
required prior to KYC approval.
Please follow the instructions below:
Forward explanation of whether the alert pertains to your client directly to compliance.
Receive confirmation from compliance that alert can be removed from the queue.
Include copies of all responses along with your KYC.
[attachment "Richard D Kahn rdc alen.pdr deleted by Amanda Kirby/db/dbcom] [attachment "Richard 0
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Kahn rdc alert_1.pdf' deleted by Amanda Kirby/db/dIxom]
Regards
Urvashi
SDNY_GM_00065128
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CONFIDENTIAL - PURSUANT TO FED. R.CON(F DB-SDNY-0027953
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EFTA01299285