diligence required. Throughout KIRBY'S time, KYC got stricter and a new KYC was required each year. Bates number 50182: KIRBY did not remember who MELISA VENEGAS [VENEGAS] was. Based on the UNCLASSIFIED//FOUO EFTA00128770 FD-302a (Rev. 5-840) UNCLASSIFIED//FOLIO 272B-NY-6764158 Continuation of FD-302 of