EFTA01370258.pdf

Deutsche Bank Compliance Population: 3+ out Population: 4+ out Population: 5+ out Population: 6+ out wires wires wires wires total it customers 122 69 41 23 sum u uust % to total It cust % to total tt cust % to total # cust % to total . $584258 i ' 24 20% . 11 16% 1 4% . $584308 r 27 22% r 12 17% I. 6 15% 1 4% . . $58<$508 .. 37 30% 17 25% 9 22% 4 17% . . v. 550K-5250K r 26 21% 16 23% 11 2rA 4 17% 5100K-5250K r 14 11% . 10 14% . 7 17% I. 2 9% $100K-$400K r 21 17% . 16 23% . 8 20% . 3 13% 5100K-5500K . 24 20% t, 19 28% 10 r, 5 22% 51008-51mm 1. 31 25% . 24 35% . 12 29% . 6 26% The orange highlights current parameters, while the green shows proposed recommendation. RECOMMENDATION For the HubMBenM rule, recommend lowering minimum transaction count from 6 to 5 and increasing the maximum aggregate transaction amount from $250,000 to $500,000. For the HubMBenLow rule, recommend lowering minimum transaction count from 5 to 4, while increasing the maximum aggregate transaction amount from $25.000 to $50.000. Rule Name Additional Details/Parameter Settings Must include at least eight (8) transactions. Cumulative amount between HubMOrgM ($100K-$400K) Must include at least three (3) transactions. Cumulative amount between HubMOrglow ($5K-$25K) Avg. Wires In per cust(excl. Month WiresIn omni account and accounts >2= wires) Vol Total Amt Vol Amt Feb-12 2,195 $ 1,854,293,691.87 4.819079 $ 4,126,703.08 For the HubSpoke rules involving multiple originators, all incoming wires for the month of February were reviewed. The average number of wires per customer and corresponding amount were calculated. It was determined that out of the 2,195 incoming wires in February 2012, the average outgoing wires per customer is 4.8 (excluding the omnibus account and those with only 1 wire for the entire month), while the total amount per customer is $4,126,703.08. A review of different dollar ranges yielded the following: http:/ db.com// 37 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0062922 CONFIDENTIAL SDNY_GM_00209106 EFTA01370258