This document is designed to assist the Relationship Manager (RM)/Investment Advisor (IA) in reviewing the certifications provided by the Account Holder, any Controlling Persons and any Ultimate Beneficial Owners as part of the Client Risk Program. It includes guidelines for affirmation and escalation in case of inconsistencies or suspicions of tax evasion.
doj/DataSet10/EFTA01377441.pdf
{"title":"Client Risk Program — Affirmation and Escalation Guideline","key_people":["Relationship Manager","Investment Advisor"],"document_type":"financial","document_subtype":"Affirmation and Escalation Guideline","key_organizations":["Deutsche Bank"],"reference_numbers":["WM167634 023496.031516","DB-SDNY-0074278","SDNY_GM_00220462","EFTA01377441"]}