Rich Kircher
About Rich Kircher
Rich Kircher, 62, serves as Deputy Money Laundering Compliance Officer (AML) for The New Germany Fund, Inc. (GF) and related DWS-advised U.S. registered investment companies. He joined the Funds in 2024 following senior anti-financial crime roles at DWS, and previously served as BSA & Sanctions Compliance Officer at Putnam Investments . As an officer, he had no beneficial ownership in GF as of May 16, 2025 and filed a late Form 3 related solely to his designation as a reporting person (no transactions), which was subsequently corrected . Fund-level compensation is not paid to officers, and no performance-linked compensation is disclosed for Kircher; TSR and operating metrics are not attributed to his role in available filings .
Past Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| Putnam Investments | BSA & Sanctions Compliance Officer | Not disclosed | Not disclosed |
External Roles
| Organization | Role | Start Date | Notes |
|---|---|---|---|
| DWS (Anti-Financial Crime & Compliance) | Senior Team Lead | Not disclosed | Core AML leadership within DWS |
| DBX ETF Trust | Deputy AML Officer | August 13, 2024 | Registered investment company AML oversight |
| DWS Trust Company | Deputy AML Officer | August 5, 2024 | Trust company AML oversight |
| Various DWS US registered investment companies | Deputy AML Officer | September 20, 2024 | Multiple fund complexes |
| DWS Distributors, Inc. | Deputy AML Officer | November 13, 2024 | Distribution entity AML oversight |
Fixed Compensation
| Item | Amount/Status |
|---|---|
| Compensation paid by GF to officers | No compensation is paid by the Fund to officers |
Performance Compensation
| Incentive Type | Metric | Weighting | Target | Actual | Payout | Vesting |
|---|---|---|---|---|---|---|
| Performance-based incentives from GF | Not applicable—GF does not pay officers | — | — | — | — | — |
Equity Ownership & Alignment
| Item | Detail |
|---|---|
| Beneficial ownership in GF (as of May 16, 2025) | None |
| Section 16(a) status | Late Form 3 filing upon designation as reporting person; no transactions; corrected |
| Shares pledged as collateral | Not disclosed in proxy filings |
| Stock ownership guidelines (officers) | Not disclosed in proxy filings; statement covers director compensation and notes officers receive no Fund compensation |
Employment Terms
| Term | Detail |
|---|---|
| Current Fund role | Deputy Money Laundering Compliance Officer (GF) |
| Tenure in current role | Since 2024 |
| Specific appointments across DWS entities | DBX ETF Trust (Aug 13, 2024); DWS Trust Company (Aug 5, 2024); various DWS US registered funds (Sept 20, 2024); DWS Distributors, Inc. (Nov 13, 2024) |
| Employment contract terms | Not disclosed in proxy filings |
| Severance / change-of-control | Not disclosed in proxy filings |
| Non-compete / non-solicit | Not disclosed in proxy filings |
Investment Implications
- Alignment and insider pressure: With no Fund-paid officer compensation and no beneficial ownership in GF, alignment with Fund shareholder outcomes via pay or equity is limited; insider selling pressure appears minimal given no reported holdings and the late Form 3 indicating a reporting designation without transactions .
- Retention and contract risk: Key employment economics (severance, change-of-control, non-compete) are not disclosed at the Fund level, suggesting that terms reside with DWS rather than GF; retention risk should be evaluated at the DWS employer level, not via Fund disclosures .
- Governance and compliance signals: The late Form 3 was administrative (designation as reporting person) and corrected; no indication of trading-related issues. From a trading-signal standpoint, filings do not point to imminent insider selling or award vesting overhangs tied to GF .
- Pay-for-performance and metrics: No Fund-level officer compensation or performance-based incentives are disclosed for Kircher. As AML roles are compliance-centric, there is no evidence of TSR or operating metrics tied to his compensation at the Fund level in the proxy materials .
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