Rich Kircher
About Rich Kircher
Rich Kircher (age 62) serves as Deputy Money Laundering Compliance Officer of The European Equity Fund, Inc. (EEA) and has held this role since 2024. He is a Director at DWS and a Senior Team Lead in Anti-Financial Crime and Compliance; he also serves as Deputy AML Officer across multiple DWS-affiliated registrants (DBX ETF Trust since Aug 13, 2024; DWS Trust Company since Aug 5, 2024; various DWS U.S. registered investment companies since Sep 20, 2024; and DWS Distributors, Inc. since Nov 13, 2024). Previously, he was BSA & Sanctions Compliance Officer at Putnam Investments. EEA filings do not attribute fund TSR, revenue, or EBITDA metrics to Kircher or to officer compensation; the Fund has no employees and pays no officer compensation.
Past Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| Putnam Investments | BSA & Sanctions Compliance Officer | Not disclosed | Senior financial crimes compliance oversight at a large asset manager |
External Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| DWS (Anti-Financial Crime & Compliance) | Director; Senior Team Lead | Current | Leads AFC/compliance functions supporting fund complexes |
| DBX ETF Trust | Deputy AML Officer | Since Aug 13, 2024 | ETF complex AML oversight |
| DWS Trust Company | Deputy AML Officer | Since Aug 5, 2024 | AML program support for trust operations |
| Various DWS U.S. registered investment companies | Deputy AML Officer | Since Sep 20, 2024 | Cross-fund AML coverage |
| DWS Distributors, Inc. | Deputy AML Officer | Since Nov 13, 2024 | Distribution/AML controls for DWS products |
Fixed Compensation
| Component | 2024 | 2025 | Notes |
|---|---|---|---|
| Base Salary | Not disclosed by EEA | Not disclosed by EEA | EEA states it pays no compensation to officers; officers are employed by DWS, not the Fund |
| Target Bonus % | Not disclosed | Not disclosed | No officer compensation disclosed by EEA |
| Perquisites | Not disclosed | Not disclosed | No officer compensation disclosed by EEA |
EEA’s proxy explicitly states: “No compensation is paid by the Fund … to officers.” The Fund has no employees and therefore no board compensation committee, reinforcing that officer pay is outside EEA and within DWS.
Performance Compensation
| Incentive Type | Metric(s) | Weighting | Target | Actual/Payout | Vesting |
|---|---|---|---|---|---|
| Cash/STI | Not disclosed | — | — | — | — |
| RSUs/PSUs | Not disclosed | — | — | — | — |
| Options | Not disclosed | — | — | — | — |
EEA provides no details on officer incentives, performance metrics, or vesting; as noted, officers are not compensated by the Fund. Any compensation would be at DWS and is not reported in EEA filings.
Equity Ownership & Alignment
| Item | Detail |
|---|---|
| Beneficial ownership (EEA common) | None (as of May 16, 2025) |
| Ownership % of outstanding | 0.00% (6,725,724.50 shares outstanding as of record date) |
| Vested vs. unvested shares | Not applicable (no holdings disclosed) |
| Options (exercisable/unexercisable) | None disclosed |
| Shares pledged as collateral | None disclosed |
| Section 16 status/filings | Late Form 3 (designation as Reporting Person only; no transactions), subsequently corrected |
| Officers/directors group ownership | 3,930 shares as a group of 13 (<1% of outstanding) |
| Ownership guidelines (officers) | Not disclosed by EEA; no employee base and no officer comp program at the Fund |
Employment Terms
| Term | Disclosure |
|---|---|
| Start date in current EEA role | Since 2024 (Deputy Money Laundering Compliance Officer) |
| Role election/renewal | Officers are elected annually by the Board following the annual meeting |
| Contract term/expiration | Not disclosed by EEA |
| Severance/change-of-control | Not disclosed by EEA |
| Non-compete / non-solicit | Not disclosed by EEA |
| Post-termination consulting | Not disclosed by EEA |
Performance & Track Record
- Compliance leadership: Multiple Deputy AML Officer appointments across DWS entities and EEA since 2024 indicate cross-platform AML responsibility.
- Reporting compliance: One late Form 3 filing (designation only; no trades), later corrected; no Form 4 transactions for Kircher are cited in the proxy.
- Fund-level performance metrics (TSR, revenue/EBITDA growth) are not discussed in connection with officer roles or compensation in EEA filings; EEA pays no officer compensation.
Risk Indicators & Red Flags
- Late Section 16 filing (Form 3) for designation as a Reporting Person; corrected (administrative issue; not a trading event).
- No legal proceedings or investigations regarding Kircher are disclosed in the proxy.
Compensation Committee / Governance Context
- EEA has no employees and has not established a compensation committee; board committees are Audit, Advisory & Valuation, and Nominating & Governance. Officer pay is not governed at the fund level.
Investment Implications
- Minimal insider-sell pressure and alignment signals: Kircher holds no EEA shares and reported no transactions; this suggests negligible direct alignment or selling pressure impact from his position.
- Compensation-related trading signals are unlikely: EEA pays no officer compensation and discloses no stock/option awards or vesting schedules for officers, limiting any event-driven trading signals tied to executive pay or vesting.
- Retention risk resides at DWS, not EEA: Officers are elected annually by the EEA Board, but employment economics (salary, incentives, severance) sit with DWS and are not disclosed in EEA filings; the Fund bears limited direct retention or parachute risk.
- Compliance oversight continuity: Kircher’s multi-entity Deputy AML roles at DWS/affiliates and EEA point to a control-focused remit rather than alpha generation; portfolio performance attribution or incentive alignment is not applicable based on EEA disclosures.