EFTA01356402 (Jun 9, 2017): KYC HR Clients Remediation process shows ABR (AML Business Risk) and AFC (Anti-Financial Crime) as separate approval steps. Lightbody held the ABR role; Franklin held the AFC role. These are parallel but distinct compliance functions.
EFTA01295997 (Oct 12, 2016): RDC alert for Epstein contains language matching what the consent order attributes to AML-2's January 2015 escalation email: "By 2011, 40 underage girls had come forward with similar stories, saying Epstein had sexually assaulted them. As of May 2013, Epstein has made 17 out-of-court settlements." ⚠️ TEMPORAL NOTE (v1.7): This document is dated October 2016 and therefore cannot be the source for AML-2's January 2015 escalation email. However, the RDC Riskography content is likely drawn from a persistent database that existed in earlier versions — AML-2 may have accessed an earlier iteration of the same Riskography data when composing the January 2015 email. The language match is significant but the causal direction cannot be established from this document alone.
Best-fit reasoning for Lightbody = AML-2:
What's missing: No document places Lightbody by name in the January 2015 escalation chain. DugganUSA searches for "Lightbody" + "ARRC", "Lightbody" + "January 2015" returned 0 hits.
Confidence: HIGH — Lightbody is the strongest candidate for AML-2 based on (a) ABR role matching the monitoring/baseline function, (b) demonstrated alert-clearing methodology ("false positive"), (c) continuous authority from Dec 2013. Definitive confirmation would require the January 2015 escalation chain with Lightbody's name.