EFTA01356402 (Jun 9, 2017): KYC HR Clients Remediation status email shows the institutional process: ABR (AML Business Risk = Lightbody's role) and AFC (Anti-Financial Crime = Franklin's role) were separate approval checkboxes, both required. Franklin and Lightbody occupied parallel but distinct compliance roles.
EFTA01388111/01388112 (May-Jul 2018): Armen Brash (now Director, 345 Park Ave) sends FinCEN CDD policy updates to full USPWM team, CC's Franklin and Yoonsun Chung. Establishes Brash as compliance policy lead with Franklin in the AFC approval chain.
Best-fit reasoning for Franklin = AML-1:
What's missing: No document places Franklin by name in the January 2015 escalation email. DugganUSA searches for "Franklin" + "ARRC", "Franklin" + "January 2015", "Franklin" + "appeals court" all returned 0 EFTA hits. The January 2015 escalation chain may not be in the DOJ EFTA production.
Confidence: HIGH — Franklin is the strongest candidate for AML-1 based on (a) continuous authority 2013-2018+, (b) behavioral pattern match (questioning, escalating, being overridden), (c) AFC role matching AML-1's described authority, (d) analytical precision in KYC challenges. Definitive confirmation would require finding the January 2015 escalation email with Franklin's name.