EFTA Document EFTA01362909

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DOJ Data Set 10

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efta-efta01362909

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Martin Zeman ; Nina Tona Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [II Classification: For Internal use only +Nina From: Zack Bunimovich Sent: Tuesday, May 08, 2018 10:21 AM To: AMLUK Reviews Jesse-J Cruz James Gladwin Cc: Kareen Johnso ; Daniel-A Klyashtorny Martin Zeman Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC Ilj Classification: For Internal use only Hi James, For ii, this is a permanent extension. Martin — can you advise on the questions from James in i. below? Thanks, Zack From: James Gladwin On Behalf Of AMLUK Reviews Sent: Tuesday, May 08, 2018 10:18 AM To: Jesse-lCruz Cc: Kareen Johnson Zack Bunimovich Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC III James Gladwin Daniel-A Klyashtorny AMLUK Reviews Classification: For Internal use only Hi both, I am happy to help. Just a couple of immediate questions to help expedite this: i. What is the business purpose for the extension? a. Elaborate on key details including; booked trades, expected volumes ii. Is the extension request permanent or temporary? a. Please provide activation/closure dates if temporary FYI, Helen has been removed from the chain as she has left the bank. AMLUK.COMPLIANCE has been removed, AMLUK.REVIEWS primarily work extensions/reactivations now alongside our PRs/EDRs and not the aforementioned team. Many thanks! - imagd)0 1.gul CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0052594 CONFIDENTIAL SDNY_GM_00198778 EFTA01362909

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DOJ Data Set 10OtherUnknown

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EFTA Document EFTA01357152

UK AFC are kindly in receipt of the KCP GM policy dated June 2017 (duly noted that this is currently under review), this document has proved useful in giving context to the UK GM product nexus with solely a US booking. Due to the local UK time, I will be discussing KCP Extensions with my management on Monday as to best understand and process such requests in the future. I truly appreciate the time and knowledge that has been shared and look forward to our conversations next week as to supp

Dept. of JusticeOtherUnknown

EFTA Document EFTA01357151

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.

Dept. of JusticeOtherUnknown

EFTA Document EFTA01357153

<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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EFTA Document EFTA01357165

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