[GRADE A1 — Internal DB AML email]
EFTA01360710 (Sep 4, 2013): Armen Brash (AML Business Risk, 60 Wall St) to Jacqueline Lightbody AND Janice Franklin (cc Amanda Kirby):
"The above named KYC has been sent to your queue; this is a high risk relationship due to the negative media and criminal convictions for Mr. Epstein. Please see previous KYC 01082293 for escalation and details."
Kirby replied asking about submitting more business accounts for Epstein.
WHAT THIS SHOWS: This is the earliest documented notification to Franklin about Epstein's criminal history. Franklin received an explicit "high risk relationship due to... criminal convictions" email on September 4, 2013 — two weeks after account opening, six days before she signed the AML Compliance approval on the KYC (9/10/2013). Franklin received explicit notification of the client's criminal history before signing the KYC approval. Combined with her continuous authority through October 2018 and her questioning of KYC structure, this establishes Franklin received Day 1 high-risk notification and is the strongest candidate for the AML Officer who later flagged emerging risks in January 2015. Kirby's reply about "a few more business accounts" shows the business line was already pushing to expand even as AML flagged the risk.