EFTA01373164.pdf
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As you know, we agreed last week at RRP to continue business as usual with Jeff Epstein based upon Chip Packard's due
diligence visit with him. I want to make sure the minutes for that meeting accurately reflect what we agreed, so I asked
AML to help re-construct the direction we had given the business. Subject to everyone's agreement, I believe the
guidance is, and should continue to be, as follows (but anyone can jump in to correct this):
The client may continue to conduct trades and transactions in existing accounts without Compliance pre-approval,
provided that the business has determined these transactions do not involve any unusual and/or suspicious activity or
are in a size that is unusually significant or a novel structure. Consistent with this, CB&S may also "open" 'eternal
accounts to facilitate activity as a booking matter where the activity has already been approved in AWM. In addition,
AML requests the business to monitor for any further developments in connection with the reputational risk review of
this client relationship and to review transaction/activity conducted in the accounts for any unusual activity.
Many thanks, Jan
Elizabeth J. Ford
Managing Director I Head of Compliance. Americas
Deutsche Bank
60 Wall Street New York. NY 1O005
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0067210
CONFIDENTIAL SDNY_GM_00213394
EFTA01373164
ℹ️ Document Details
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5e99f1121458bd7d549a63ddae67aac024a636a6c86fbb7238e5389c064ba693
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EFTA01373164
Dataset
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document
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1
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