EFTA Document EFTA01356672

Due to the suspension of the code delivery for interdivisional KYC attestation process, WM clients will be on boarded onto GM platforms directly. The business is required to outline the issues and remediate the risks attached. Absent of remediation puts the business at risk for not meeting some of the Compliance and AFC requirements. The remediation plan needs to be created and attached. Remediation should include but not limited to — 1- Identifying client population that has derivative transactions need to be classified as per MIFID II. 2- creating an opt up professional process for the WM clients as GM does not service Retail clients. 3- creating a process for identification of the deltas in KYC. 4- creating KOPs for the overall process. 5- Identifying the Brexit requirements. Thanks, Funda Bozkurt Deutsche Bank Trust Company Americas. WM-Divisional Control Office 345 Park Avenue 10154.0004 New York. NY, USA Tel. il Email Original Appointment From: Victoria Bruce Sent: Wednesday, February 13, 2019 3:16 PM To: Victoria Bruce; Funda Bozkurt; Thomas Klemm; Kimberly Hart; Puzant Merdinian; Steven Mattus; Olivier Poncet; Ian Salters; Andrea DeMar; Bill King; Jeffrey Roth Subject: FW: Client OTC derivatives trading with CIB (I] When: Friday, February 15, 2019 2:30 PM-3:15 PM (UTC+00:00) Dublin, Edinburgh, Lisbon, London. Where: Dial in below Classification: For internal use only Pin: CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042659 CONFIDENTIAL SDNY_GM_00188843 EFTA01356672