EFTA01299239 (Dec 4, 2013): Andrew Kisz forwards Lightbody-cleared alert to Kirby. Lightbody approving AML clearances for Epstein entities from December 2013 — just 3 months after the initial KYC approval.
WHAT THIS SHOWS AND DOES NOT SHOW: This confirms Lightbody was actively clearing alerts for the Epstein relationship from very early on — not just the September 2013 KYC signing but ongoing alert management by December 2013. Combined with her role clearing Kahn's RDC alert as "false positive," this establishes Lightbody as having continuous AML authority from the start of the relationship. This is consistent with either AML Officer-1 or AML Officer-2 in the consent order.