Exhibit 103 — Videotape Deposition via Zoom (Case 1:20-cv-00658-LMB-IDD Document 142-4)
Factual Summary
Grice testifies Chain Bridge's brief pause in contacting Gula on March 25-26 was "a small pause for a few hours while the bank performed the necessary diligence," not a cutoff, and that senior management wanted to "control the conversation" to avoid inconsistent messaging. He testifies Chain Bridge's document requests (twice asking for contracts, never provided) were reasonable and that a screenshot Gula supplied was "very low quality information" insufficient to support the transaction to the OCC. He rejects that capital-ratio urgency motivated the bank's actions ("I don't see any evidence that this motivated the actions taken by Chain Bridge at all"), attributing the ICS-related emails to prudent contingency planning instead. He testifies contacting a counterparty bank's own client directly — which several other witnesses called unusual — is, in his banking experience, normal practice, illustrating with an anecdote of his own bank contacting a "church" customer's counterparty and discovering a misrepresentation. Grice calls the bank's afternoon-of-the-26th decision to end the relationship "perfectly reasonable given what they had just experienced." Asked about California's later conduct, Grice testifies he was unaware, until asked in this deposition, that "California ultimately... wired... half a billion dollars to a Chinese company that had never made masks before and is now in receipt of those masks."
Key Facts
- New fact, disclosed through cross-examination rather than affirmatively documented elsewhere in this docket: California reportedly completed a subsequent wire of roughly $500 million to a different, previously-inexperienced Chinese mask manufacturer after the Blue Flame transaction was cancelled — put to the witness by counsel, not independently confirmed here.
- Grice directly disputes that capital-ratio concerns motivated Chain Bridge's conduct, in tension with Richardson's internal emails (Exhibits 29/59) citing "problems on our capital ratios," and with Williamson's own recorded comment about "a really big impact on our capital ratios" (Exhibit 101/142-2) — reproduced as the expert's contrary opinion, not adjudicated.
- Grice defends direct counterparty-client contact as standard practice, contrasting with Schoeppe's disclaimed knowledge on the same point (Exhibit 102/142-3).
- Grice declines to opine on whether the deposit size was a capital-reserve concern for a bank Chain Bridge's size: "that's not my expertise."
Source Caveats
- Marked Confidential; excerpted testimony only.
- The California-$500-million-wire claim is put to the witness by opposing counsel during cross-examination; Grice states he had no prior knowledge of it, and this summary does not treat it as an established fact.
- Grice's opinions are his own expert conclusions retained by the defense and are attributed as such, not treated as adjudicated findings.
- Date
- 2021-05-20
Cite this document
“Exhibit 103 — Videotape Deposition via Zoom (Case 1:20-cv-00658-LMB-IDD Document 142-4).”
Original at ecf.vaed.uscourts.gov, dated 2021-05-20. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2021-05-20-page-1-v-chain-bridge-bank-n-a/
, SHA-256 9a4c943e6ae9157197a72070cb258cf400164e922352335bf68a65f895b01178.Full text
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EXHIBIT 103
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CONFIDENTIAL
Page 1
1 CONFIDENTIAL - CHARLES H. GRICE VOL. I
2 US DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
3
BLUE FLAME MEDICAL LLC,
4 Plaintiff,
v. Civil Action No.
5 CHAIN BRIDGE BANK N.A., 1:20-cv-00658
JOHN J. BROUGH, and DAVID
6 M. EVINGER,
Defendants.
7 X
CHAIN BRIDGE BANK, N.A.,
8 Third-Party Plaintiff,
v.
9 JP MORGAN CHASE BANK,
N.A.,
10 Third-Party Defendant.
11
12 VIDEOTAPE DEPOSITION VIA ZOOM OF:
13 CHARLES H. GRICE VOLUME I
14 FRIDAY, APRIL 9, 2021
15
16
17
18
19
20
21
22
23
24 REPORTED BY:
SILVIA P. WAGE, CCR, CRR, RPR
25 JOB NO. 4528853
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Page 2 Page 4
1 CONFIDENTIAL CHARLES H. GRICE VOL. I 1 CONFIDENTIAL CHARLES H. GRICE VOL. I
2 2 A L S O P R E S E N T:
3 3
ETHAN BEARMAN, ESQ.
APRIL 9, 2021
4 BLUE FLAME MEDICAL LLC
4 7:59 A.M. CENTRAL
5
5 Videotape deposition via Zoom of GABRIEL TORRES, ESQ.
6 CHARLES GRICE VOLUME I, pursuant to agreement 6 JP MORGAN CHASE
7 before SILVIA P. WAGE, a Certified Shorthand 7
8 Reporter, Certified Realtime Reporter, Registered JOSHUA GLICK, ESQ.
9 Professional Reporter, and Notary Public for the 8 JP MORGAN CHASE
10 States of New Jersey, New York and Pennsylvania. 9
11
ROBERT RUDIS
10 VIDEOGRAPHER
12
11
13 12
14 13
15 14
16 15
17 16
18 17
19 18
19
20
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21
22 22
23 23
24 24
25 25
Page 3 Page 5
1 CONFIDENTIAL - CHARLES H GRICE VOL I 1 CONFIDENTIAL CHARLES H. GRICE VOL. I
2 A P P E A R A N C E S:
2 I N D EX
SCHULTE ROTH & ZABEL LLP 3 WITNESS: CHARLES H. GRICE PAGE
4 Attorneys for Plaintiffs Blue Flame Medical LLC
919 Third Avenue
4 EXAMINATION BY MR. WHITE 10
5 New York, New York 10022 5 EX H I B I T S
(212) 756-2000 6 NO. DESCRIPTION PAGE
6 Pete white@srz com
Angela garcia@srz com 7 Exhibit Pl 16 Expert Report of Charles H. 14
7 Nathaniel palrner@srz com Grice February 12, 2021
8
Gregory ketcharn-colwill@srz com
Kenny ukabiala@srz com
8 Exhibit Pl 17 Appendix B to Subpart B of 114
BY: PETER WHITE, ESQ Part 210 Article 4A, Funds
9 BY: ANGELA GARCIA, ESQ 9 Transfers
10
ROBBINS, RUSSELL, ENGLERT, ORSECK, UNTEREINER &
Exhibit P118 § 4A 2 l l . Cancellation and 191
11 SAUBER LLP 10 Amendment of Payment
Attorneys for Chain Bridge Bank, NA Order., U.C.C. Text §4A 21 l
12 2000 K St NW 4th floor
Washington D C 20006 11 Exhibit Pl 19 § 4A 404. Obligation of 229
13 (202) 775-4500 Beneficiary's Bank to Pay
Mrnadden@robbinsrussell com
14 Lesbrook@robbinsrussell com
12 and Give..., U.C.C. Text§
Gorseck@robbinsrussell com 4A 404
15 BY: MATTHEW MADDEN, ESQ 13
BY: LESLIE C ESBROOK, ESQ
16 BY: GARY ORSECK, ESQ 14
17 15
WILMER HALE CUTLER PICKERING & DORR LLP
18 Attorneys for J P Morgan Chase and Deponent
16
7 World Trade Center 17
19 250 Greenwich Street 18
New York, New York 10007
20 (212) 230-8800 19
Alan Schoenfeld@wilrnerhale com 20
21 Albinas Prizgintas@wilrnerhale com 21
Maris.sa Medine@wilmerhale com
22 BY: ALAN SCHOENFELD, ESQ 22
BY: ALBIN AS PRIZGINT AS, ESQ 23
23 BY: MARISSA MEDINE, ESQ
24
24
25 25
2 (Pages 2 - 5)
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2 did not receive sufficient information from Blue 2 the afternoon on the 26th. So it is not it
3 Flame Medical as to how they would satisfy the 3 was the morning of the 26th where there is a
4 purchase order; am I characterizing your 4 pause.
5 testimony correctly? 5 Q. I understand the concern about
6 A. I'm comfortable with that, yeah. 6 cross talk.
7 Q. Did Chain Bridge Bank contact Blue 7 Did senior management at the bank
8 Flame Medical to try to get additional 8 contact Mr. Gula so that there wouldn't be any
9 information about how they were going to fill the 9 cross talk?
10 purchase order? 10 MR. MADDEN: Objection to form.
11 A. My understanding from the record is 11 A. They had they had asked Mr. Gula
12 they asked twice, once on the phone call with 12 twice just on the documents, right, just on the
13 Gula and once in a follow up e mail. They looked 13 contracts. He did not provide them.
14 forward to receiving the contract. 14 So I know they could have asked a
15 Q. Is it normal practice for a bank 15 third or a fourth or a fifth time. I don't know
16 A. exist. 16 if that would have changed the outcome. But it's
17 Q. communications with its customer 17 important when somebody asks you a question in an
18 at that point? 18 urgent situation like this to be responsive.
19 THE STENOGRAPHER: I'm sorry, I 19 Q. Well, he was responsive orally during
20 wasn't quick enough. There was cross talk. 20 the phone conversation, he told them where the
21 Q. Is it normal for a bank 21 masks were going to come from, didn't he?
22 A. (INAUDIBLE.) 22 A. But that's different. That's telling
23 Q. to cut off all communications with 23 me kind of where's Waldo. That's giving me some
24 its customers during its due diligence 24 indication of what country they're going to be
25 investigation? 25 produced in is one thing.
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2 A. I still didn't hear the question, I'm 2 I need to be able to see contracts,
3 sorry. 3 signed contracts that I can tie off against the
4 Q. Is it normal for a bank to cut off 4 size of the transaction.
5 all contact with its customer during a due 5 Q. And why do you
6 diligence investigation? 6 A. So that's why the screen shot the
7 A. I don't see this is cutting anything 7 screen shot from Mr. Wong, for example, this is
8 off. I thought it as a small pause for a few 8 information, but the content of the information
9 hours while the bank performed the necessary 9 is I would argue quite low, right, it's poor. I
10 diligence. 10 don't know what this is, right. It's not I
11 Q. If Chain Bridge Bank was interested 11 can't rely on that. So that's not the kind of
12 in obtaining this information from Blue Flame, 12 information I can show the OCC and back up to the
13 why did they block all contact with Blue Flame? 13 transaction. So it's not it's not zero
14 MR. MADDEN: Objection to form. 14 information. It's just very low quality
15 A. Because they wanted as I read the 15 information.
16 record, it was senior management at the bank 16 Q. Why as the beneficiary bank do you
17 wanting to control the conversation to make sure 17 need information about the source of supply?
18 that, basically, the bank wasn't engaged in 18 A. Because this transaction is now on
19 cross talk with the client so they wouldn't have 19 the back of Chain Bridge. As the wire arrives to
20 consistent messaging. It was also to give them 20 Chain Bridge, a hundred percent of the
21 time to perform the necessary diligence. 21 responsibility of getting this thing correct is
22 We are talking about we're talking 22 on the back and the reputation of Chain Bridge
23 about very few hours, right. We're not talking 23 Bank and for Jimmy.
24 about a day. We're talking about very few hours. 24 Q. If Chain Bridge Bank had all of these
25 I think Gula comes to the back at 2 o'clock in 25 concerns about this wire that they were told was
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2 going to come the next day, why didn't they block 2 which whether it was Bearman or Thomas. I
3 it? 3 think it was Thomas was confidentially there
4 MR. MADDEN: Objection to the form. 4 going to be billions of dollars moving through
5 A I don't know the answer to that 5 this account through the next several weeks.
6 question. I just don't know. I don't know if 6 This isn't helpful, right.
7 you asked them. I don't recall if you asked them 7 What you don't want if you're a
8 or if they answered it. 8 banker is to be used in to be used in a
9 Q. If they had all these concerns, 9 process where your control and insight into the
10 should they have blocked it? 10 business is very limited. Nobody wants to be
11 MR. MADDEN: Same objection. 11 used as a conduit.
12 A I, you know, I just that's kind of 12 And, you know, as I read the record,
13 hypothetical. I don't know. I mean, I don't 13 I got chilled by what it appeared to be, which is
14 think honestly, as I read it, I don't know if 14 these guys are moving very fast. This may not be
15 I even believed it was going to occur given what 15 the good step for Chain Bridge that it was on the
16 I had seen that day. You know, I know he 16 morning of the 25th. You know, a certain wire
17 describe first of all, it's a brand new 17 volume, a certain number of wires might be a good
18 business, right. It's just been created. He 18 match for our risk appetite. Billions of dollars
19 describes the business. Then he comes in and 19 of wires in a short period of time may not fit.
20 lobs this bigger surprise, which renders his 20 This may not be a business we want to get into.
21 first kind of prognosis it just cast a lot of 21 We didn't have that decision until the 26th.
22 doubts on it, right. 22 Q. Well, I thought you said they could
23 So now we have giant wire coming in, 23 have blocked it on the 25th when they had these
24 which has a lot of very suspicious loose ends. 24 concerns.
25 And so the number of questions I have to resolve 25 Didn't you say that?
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2 goes up as we go through the 25th, not down. I 2 A On the 25th on the 25th, we
3 have more diligence I have to do now than I had 3 learned about the California wire transaction.
4 to do on the morning of the 25th. You know, I 4 On the 26th, as I understand the record, we
5 still have an extremely unusual I now on 5 started then hearing talk about billions of
6 the morning of the 26th, I now have the 6 dollars of wires. So that's not the same thing
7 transaction. So the work has to shift from the 7 as $75 million in wires.
8 hypothetical to the practical of what do we do 8 Q. You say "we" there.
9 now, but I find it more complex. 9 You're aligning yourself as "we," you
10 Q. Given the questions that existed 10 and Chain Bridge, correct?
11 prior to the wire transfer, would you have 11 A Well, I'm you know, culturally I'm
12 advised Chain Bridge Bank if you were advising 12 a banker, so I'm in the banker's shoes. I don't
13 them to block the transfer from occurring in the 13 mean I'm not speaking for Chain Bridge,
14 first place? 14 certainly.
15 A I you know, my inclination would 15 As I look at the facts in this
16 be to say, no, because I would I would want to 16 transaction, you know, I'm naturally kind of
17 work with the customer to see if there's a way to 17 looking at the facts from the point of view of a
18 make this thing function, is there a way to make 18 banker. So I studied the Chain Bridge record
19 this successful. 19 most closely. So that's the "we." I don't mean
20 Q. And how did Chain Bridge Bank work 20 to imply
21 with the customer to make it successful? 21 Q. It goes to point of view of the
22 A They said, tell us what's happening, 22 banking customer?
23 you know, give us your best estimate. And that 23 MR. MADDEN: Objection to form.
24 was wrong. Then we find out about the actual 24 Q. Is that the explanation?
25 transaction. Then we hear comments and I forget 25 A No, what I said is true. I studied
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2 a balance sheet. As you know, the reserve 2 caused an enforcement action. I think if they
3 requirements that apply to banks were basically 3 never obtained it, they would be criticized,
4 suspended the beginning of March. I just I 4 certainly, for flying blind on a transaction.
5 don't see the urgency and I don't see any 5 Q. It's normal in the process of
6 evidence that this motivated the actions taken by 6 diligence in a transaction like this for a
7 Chain Bridge at all. 7 customer to be in regular or a bank, sorry, to
8 Q. You don't consider all of the e mails 8 be in regular contact with its customer, isn't
9 that talk about the urgency of not having this on 9 that correct?
10 their balance sheet as any evidence that that was 10 A. I really don't know if there's a
11 a motivation here for Chain Bridge Bank, you 11 practice or a rule about that. I think typically
12 don't see that? 12 well, this is not typical in the slightest.
13 A. What I see when I read that is this 13 But, you know, in my experience, we want to keep
14 is kind of the proper implementation planning I 14 our customers close. This is extraordinary. You
15 would want my team to engage in, if they were 15 know, you've got extenuating circumstances given
16 confronting a transaction like this. They don't 16 that the birth of Blue Flame was just on the
17 know how real it is. So they want to be ready 17 heels of the arrival of this wire. So I've never
18 just in case. And so I saw, you know, kind of 18 seen this combination of facts before.
19 reasonable, serious discussions and actions being 19 Q. Did Chain Bridge Bank act like it
20 taken, you know, winding up the ICS, getting the 20 wanted to keep this customer Blue Flame Medical
21 ICS application to Gula. They were taking the 21 close?
22 steps you would want them to take, but they're 22 A. I think so, yes. I mean, the
23 still operating with a deficit of information. 23 difficulty is keeping somebody close during the
24 So we don't know we just don't 24 second or third week of the COVID pandemic is
25 know the scale of this shock to the balance 25 sort of an kind of oxymoron. I don't want
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2 sheet. We just don't know how long the cash is 2 anybody in my office, right. I don't know if you
3 going to be there. So I just don't share 3 went to any bank branches
4 Mr. O'Malley's certainty about the scale of the 4 Q. I did.
5 problem or the constraint this would place on 5 A. on the 25th or 26th of March
6 Chain Bridge's behavior. 6 you did?
7 Q. You see any evidence that they 7 Q. Yes.
8 contacted Mr. Gula to find out about this 8 A. Well, I did not. I am not that
9 information about how long the money would remain 9 brave. The protocols of the rules just weren't
10 in the account? 10 in place yet. We didn't have the habits. But my
11 A. I don't remember if he shared that 11 recollection is my clients didn't want to see me.
12 information. So I I'm just foggy on what, if 12 My clients didn't want to see their clients. We
13 anything, Gula provided. But, as I said a few 13 were everybody was standing down and most of
14 minutes ago, the most important information the 14 us were staying home.
15 bank needed was the contracts. They needed to be 15 Q. Alright. I take it you're not giving
16 able to look at the vendor contracts and assess 16 your expert opinion on that issue?
17 the reality of Blue Flame Medical purchasing a 17 A. No, I'm giving you my personal
18 hundred million N95s. That's an essential hurdle 18 experience.
19 that has to be cleared. 19 Q. Okay. Is it normal for a bank
20 Q. Are you saying if that hurdle was not 20 conducting a BSA diligence investigation to cut
21 cleared, they would face sanction from the OCC if 21 off contact with its own customer and at the same
22 they allowed this transaction to go into Blue 22 time contact directly the client of its
23 Flame Medical's account? 23 counterparty bank; is that normal in a BSA
24 A. You know, there's so many parts of 24 investigation?
25 this, Mr. White. I don't know if that would have 25 A. I
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2 MR. MADDEN: Objection to form to 2 with this many kind of suspicious
3 form. 3 characteristics, that's not sufficient. I want
4 A. I reject the characterization as 4 to look at more information. So I'm going to,
5 cutting off. This is a pause. It's a few hour 5 basically, square that information against other
6 pause in the conversation. You know, they met 6 information.
7 with Gula off and on throughout the bank met 7 So the other information banks
8 with Gula on and off throughout the 25th. They 8 routinely gather is, you know, web search,
9 resumed meeting early in the afternoon of the 9 Internet information, Google hits, news about the
10 26th. I just don't see that as a cutoff. 10 originator, you know, trying to build a profile
11 Evinger and Brough hunkered down and 11 for what does this originator do. So is what I
12 wanted to control the messaging with Gula. 12 can learn about it match what my customer has
13 Perfectly reasonable and it lasted a few hours. 13 told me they do.
14 So, I guess, I just reject the characterization 14 And then if doubts persist, again, in
15 that this was a cutting off. I don't know if 15 particular, against the backdrop of an extremely
16 Q. Okay. Is that sort is that sort 16 large transaction, I am free to call the
17 of pause normal? 17 originator.
18 A. Sure. It's normal in particular with 18 Q. So the ordinary course would be to
19 the new client. I have to go through an exercise 19 gather information from your own client, that's a
20 with a new customer of trying to assess, you 20 normal thing to do, correct?
21 know, can I work with them or do I understand how 21 A. Right, as was done here.
22 they work and can we find a way to work together. 22 Q. And to gather information from public
23 And so the 25th was dedicated for 23 sources, Google searches and so on about both
24 pulling in information from Mr. Gula. The 26th 24 parties to the transaction, correct?
25 was trying to make sense the morning of the 25 A. Correct. And, you know, J.P.
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2 26th I'm trying to make sense of the information 2 Morgan's version of this was to go to the early
3 that he provided. 3 warning system software, which is a risk scoring
4 The afternoon of the 26th the bank 4 methodology. But it's effectively doing the same
5 came to the determination it appears that the 5 thing. It's searching for public source
6 risk of this relationship was not consistent with 6 information and trying to risk rate or identify
7 the bank's appetite, which is a decision that 7 doubts that may exist from certain customers.
8 really only the bank can make and I support that 8 So when you see I forget if it's
9 decision. So the termination of the account 9 Coffey or Korpal who says, you know, one of the
10 relationships related to Red Line and Blue Flame 10 difficult aspects of this transaction was the
11 on the afternoon of the 26th, I think, was 11 lack of sort oflnternet presence at all. So you
12 perfectly reasonable given what they had just 12 can't do that public source search for a brand
13 experienced in the 24 hours prior. 13 new company that has no track record.
14 Q. Is it also normal for a bank to 14 But these are the the normal step
15 contact the counterparty to the wire transfer 15 is to first go to my customer and then go to
16 directly as opposed to their banking 16 public source or proprietary software systems and
17 counterparty; is that normal? 17 then to the extent that doubts persist, which,
18 MR. MADDEN: Objection, objection to 18 you know, was going to happen when have extremely
19 form. 19 large wire transaction like this, if you feel
20 A. Yes, sir. I talk to originators of 20 it's appropriate, call up the originator.
21 wires routinely to try to understand what the 21 Q. The ordinary next step would be to go
22 transaction represented. So, if I'm in the 22 to the originator's bank, wouldn't it?
23 receiving bank, I need to understand. My one 23 A. Sometimes but not always. I've done
24 early source of information is my client, right, 24 both. I've gone I've done physical site
25 the beneficiary. That for a large transaction 25 visits to the originator. I've, certainly,
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2 contacted the counterparty, the other bank to try 2 can be directly helpful to our due diligence
3 to understand what they understand. So it 3 obligations and vice versa.
4 depends on it depends on protocols and time 4 Q. Are you saying that the other folks
5 and the availability of people. 5 we've talked to in this area you said it's
6 Q. Have you contacted an originator 6 very unusual to contact the originating bank's
7 directly without letting the corresponding bank 7 customer directly as a beneficiary bank.
8 know? 8 Are you saying they're wrong?
9 A. Certainly. 9 A. Yes, to the extent that I understand
10 Q. How often does that happen? 10 what they're saying, I think, they're incorrect.
11 A. So I am now the Chief Compliance 11 Q. Okay. Are you aware that California
12 Officer for a bank in New York that does regular 12 ultimately after this transaction was cancelled
13 wire transfers with a bank in California. And 13 wired over a half million dollars half a
14 I'd say once month to month I direct bank 14 billion dollars to a Chinese company that had
15 employees in New York to call originators in 15 never made masks before and is now in receipt of
16 California to understand what a transaction 16 those masks? Are you aware of that?
17 represents. 17 A. I did not know that, no.
18 And the reason for that is we have a 18 Q. Now, are you aware of that, are you
19 couple of customers who are involved in one's 19 saying that that's a transaction that should not
20 in import/export and one is in real estate 20 have been allowed to occur?
21 development. And both of these customers are 21 A. I don't know. I don't know the facts
22 fall into this trap of not being transparent. So 22 on that transaction and how it unfolded. I know
23 when we ask the customer, our customer, what is 23 the facts in this transaction.
24 this inbound wire that you're receiving from this 24 Can I put in a request for a very
25 company out in the West Coast, the answer we get 25 short? Can we do two or three minutes or
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2 is vague, like, it's from another trading company 2 five minutes or whatever
3 or in one case we were told, this represents 3 Q. You can do that?
4 money from a church. 4 A. you will allow?
5 And so we called the church and we 5 MR. WHITE: Let's go off the record.
6 learned that it took a few calls. We learned 6 A. Okay, thank you.
7 that the church, in fact, was a real estate 7 THE VIDEOGRAPHER: We are going off
8 developer. So the customer had lied to us about 8 the record at 3:22. This marks the end of Media
9 the nature of the relationship and the nature of 9 Unit No. 6.
10 their counterparty. So this happens routinely. 10 (Recess taken 3:22 to 3:30 p.m.
11 Customers sometimes don't tell you the truth. 11 Central.)
12 And that's why you have to use, you know, 12 THE VIDEOGRAPHER: We are back on the
13 alternative methods to try to obtain information. 13 record at 3:30. This marks the beginning of
14 Q. Did you let the bank in California 14 Media Unit No. 7.
15 know that you were going to be contacting the 15 Q. Mr. Grice, for a bank the size of
16 customer directly before you did so? 16 Chain Bridge in March of 2020, can a deposit the
17 A. We did after we had this example that 17 size of the one that was sent here be a concern
18 I just told you about where our customer said it 18 with regard to the bank's capital reserves?
19 was a church and when we called their customer we 19 A. I don't opine on that. I don't offer
20 learned it wasn't a church but it was a real 20 an opinion on it.
21 estate developer. We shared that information. 21 Q. Do you know? You said you were a
22 Because, again, we've got a relationship with the 22 bank this size.
23 bank, right. The beneficiary and the originating 23 A. Sure. But I don't do, you know,
24 bank have a relationship and that relationship is 24 balance sheet analysis. That's not my expertise.
25 important because sometimes their due diligence 25 It's not that's not what I do.
75 (Pages 294 - 297)
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