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EFTA01299299.pdf
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LI Current Classification: (click here for help) Internal Revised_CLEARED_Richard D Kahn rdc alert [I] PWMUS AMLKYC to Amanda Kirby 11/01/2013 10:54 AM Sent by: Michael Vila Cc: Jacqueline Lightbody. PWMUS AMLKYC, Janice Franklin 2 attachments Richard D Kahn rdc alert_1.pdf Richard D Kahn rdc alert.pdf 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 CAI Michael Vila Team Manager I AML Compliance Deutsche Bank Securities Inc. Moak ft Wealth Mananernent Pascitntiv Palbast. Amanda Kirby—0910412013 11:09:44 AM—Classification: For internal use only Hi, The below RDC alerts do pertain to our client. Richard D SDNY_GM_00065153 IDENTIAL CONFIDENTIAL - PURSUANT TO FED. R.QQN(F DB-SONY-0027978 EFTA_00 175653 EFTA01299299 From: Amanda Kirby To: PWMUS AMLKY , Andrea Klingenber Cc: Urvashi LavaniardlYdbcom PWM BIS-Researca Paul M Date: 02042013 11.09 AM Subject Re: Richard D Kahn rile alert 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 (.ee attachedf ile: Richard D Kahn rdc aleapc(1) (See attachedf ile: Richard D Kahn rdc alert 1.p d/? 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 Front To: Amanda Ki Cc: Date: 0943/2013 0422 PM Subject: Richard D Kahn rde alert Ill 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 alert.pdf' deleted by Amanda Kirby/db/dbcomi [attachment "Richard 0 SDNY_GM_00065154 IDENTIAL CONFIDENTIAL - PURSUANT TO FED. R.ctON(F DB-SDNY-0027979 EFTA_00175654 EFTA01299300 Kahn rdc alert_1.pdf' deleted by Amanda Kirby/db/dbcom] Regards Urvashi SDNY_GM_00065155 IDENTIAL CONFIDENTIAL - PURSUANT TO FED. R.Qc-b-M(F DB-SDNY-0027980 EFTA_0017 5655 EFTA01299301