The DBUS AML Compliance Unit will conduct quarterly assessments on ten randomly selected New Client Adoptions files affected by CRE to evaluate the adequacy of AML aspects in the new client adoption process. The assessment focuses on AML compliance, including Customer Identification Program elements and escalation processes for higher risk accounts. The review is applicable to new client adoptions in the CRE Loan Origination and CRE Syndicated Loan desks, excluding loans purchased for securitization. The process involves communication with CRE Business Managers, obtaining a list of new client adoptions, random file selection, and detailed file review.
doj/DataSet10/EFTA01372647.pdf
{"title":"Quarterly CRE AML/NCA File Assessment","document_type":"correspondence","document_subtype":"assessment report","key_organizations":["DBUS AML Compliance Unit","CRE Loan Origination","CRE Syndicated Loan desks","Deutsche Bank Group"],"reference_numbers":["DB-SDNY-0066436","SDNY_GM_00212620","EFTA01372647"]}