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efta-efta01362904DOJ Data Set 10Correspondence

EFTA Document EFTA01362904

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From: Sent: To: CC: Nicholas Hislop 5/21/2018 12:07:32 PM Kareen Johnson Simon Nall Martin Zeman Nina Tona AMLUK Reviews ~; Ian Salters Zack Bunimovich Daniel-A Klyashtorny Xavier Avila • Davide-A Sferrazza Devshiji Odedra Ricky-x Patel - ~: Jonathan Whittle James Gladwin Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC ill Classification: For Internal use only Hi Kareen, Jesse-J Cruz Is this not because the client is High risk and therefore all extensions are routed to AFC, and/or the Global KYC was out of date? Therefore the completion of the global triggered the local requests for review? From: Kareen Johnson Sent: 21 May 2018 12:34 To: Nicholas Hislop < > Cc: Simon Nall Martin Zeman Daniel-A Klyashtorny , Nina Tona Xavier Avila ., IDavide-A Sferrazza AMLUK Reviews Devshiji Odedra Ian Salters Ricky-x Patel ; Jesse-J Cruz ; Zack Bunimovich • >; Jonathan Whittle James Gladwin ~ fr Subject: Re: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC Good day Nick - We have an issue here where in dbCAR this relationship did not reflect an old GB review date. We can see in the master profile that the relationship was created several years ago under DBAG, but now when extending for a new product, the review was missing completely. The file was escalated to AML for review and approved . This action triggered a GB review date for the very first time. Is it possible this was a merger issue? Please let me know if your team could take a look and if additional information is needed. Thank you! Kareen Johnson On May 18, 2018, at 12:11 PM, James Gladwin wrote: Classification: For internal use only Hi Simon, Absolutely, quite simply: i. Our Jacksonville CDS colleague, Kareen Johnson, will be reaching out to the dbalENT merger team to query the status/success of the KCP merge from dbCLIENT to dbCAR a. @Kareen, it would be great if I could be CC'd in to your correspondence so that AFC can be advised accordingly CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0052589 CONFIDENTIAL SDNY_GM_00198773 EFTA01362904

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a. KCP clients had migrated from dbCLIENT to dbCAR, potentially the migration did not complete correctly (this will continue to be investigated SEPERATELY to this Extension request) b. At the very first adoption of the client/extension to UK GM products, this was not correctly booked within our internal systems iv. Fixes to the dbCAR profile were discussed between Global CDS teams, of which the latter was chosen due to time constraints and the impact upon our first line colleagues; a.

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<imagc001.gir- fames Gladwin AFC Business Advisory Anti-Financial Crime DBOI Global Services (UK) Limited S Brindle Place, Birmin ham B1 21B, United Kingdom Emai mg Please consider the environment before printing this email From: Martin Zeman Sent: 08 May 2018 20:27 To: Zack Bunimovich AMLUK Reviews ;Jesse-J Cruz ; James Gladwin areen o nson ; Daniel-A Klyashtorny ; Nina Tona er Avila Davide-A Sferrazza Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC

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