¶ STRONG CANDIDATES (BATCH 45-50 FINDINGS)
[GRADE A2 — KYC approval documents + internal DB emails]
EFTA01384073, EFTA01360693/684/687/689
Full title: "Janice Franklin, CAMS, CFSA, CFIRS — Vice President | AML Compliance Officer — Deutsche Bank Trust Company Americas — Compliance — 60 Wall Street"
Evidence for AML Officer identification:
- Signed AML Compliance approval on Epstein KYC 9/10/2013 (EFTA01384073) — she literally approved Epstein's AML compliance status
- QUESTIONED KYC structure re Southern Financial relationship mapping — asked how personal accounts were connected to Southern Financial (EFTA01360693)
- Senior AML specialist certifications: CAMS (Certified AML Specialist), CFSA (Certified Financial Services Auditor), CFIRS
- Located at 60 Wall Street — compliance office, separate from 345 Park Ave banking team
- She was actively reviewing Epstein KYCs, not rubber-stamping them — good compliance questions but ultimately approved
WHAT THIS SUGGESTS: Franklin is now assessed as AML Officer-1 (see SVE-07), not AML-2. Her behavioral pattern — questioning KYC structure, demanding Legal sign-off, escalating — matches AML-1's described behavior of flagging risks and pushing back. This section is retained for historical context but Franklin is no longer a candidate for AML-2.
¶ 🔥🔥🔥 Jacqueline Lightbody — AML Business Risk
EFTA01384073, EFTA01299321/283/239
Evidence for AML Officer identification:
- Signed AML Business Risk approval on Epstein KYC 9/10/2013 (EFTA01384073)
- Member of PWM US AMLKYC team — cleared Richard Kahn RDC alert as "false positive"
- Worked alongside Franklin in the AMLKYC team
- Had authority to clear alerts for Epstein associates (cleared Kahn)
WHAT THIS SUGGESTS: Lightbody signed off on AML Business Risk for the initial Epstein KYC. Her role in clearing alerts for Epstein associates shows she had ongoing AML authority in the relationship. Either Franklin or Lightbody could be AML Officer-1 or AML Officer-2.
The KYC approval document (EFTA01384073) shows the FULL approval chain:
- Jacqueline Lightbody signed as "AML Business Risk" — matches AML Officer role
- Janice Franklin signed as "AML Compliance" — matches AML Officer role
- Franklin QUESTIONED the KYC structure but ultimately approved
- Both at 60 Wall Street, separate from banking team at 345 Park Ave
- These are STRONG CANDIDATES for AML Officer-1 and AML Officer-2 from the NYDFS consent order