EFTA Document EFTA01363029

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DOJ Data Set 10

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I truly appreciate the time and knowledge that has been shared and look forward to our conversations next week as to support each other. Many thanks all, lames Gladwin AFC Business Advisory Anti-Financial Crime DBOI Global Services (UK) Limited A Please consider the environment before printine thi: email From: James Gladwin Sent: 10 May 2018 09:47 >; Zack Bunimovic >; Jesse-1 Cruz= Cc: Kareen Johnso >; Daniel-A Klyashtorny < >; Nina Tona vier vi a < Davide-A Sferrazza ; AMLUK Reviews a Devshiji Odedra Subject: RE: Escalation: ONB-1135648 / LKYCGB-16O049 / Southern Financial LLC [II Classification: For Internal use only Hello all, Do we have BRG approval for this? This is appears to be a cross-jurisdictional adoption from DBSI to DB AG, furthermore, the LRO for the US is 2016 and does not appear to be in the Remediation pipeline? For Extensions to be approved, AFC UK require: i. BRG approval to consider cross-jurisdictional approvals which result in newly booked High Risk clients ii. The file to be within NRD date and if not, must be within the Remediation pipeline — of which it appears it is neither @CDS colleagues, Please consider the above points, I am happy to further explain on the phone to assist our business colleagues & clients expectations. @Martin I will keep you updated on the progress made. Many thanks all, lames Gladwin AFC Business Advisory CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0052862 CONFIDENTIAL SDNY_GM_00199046 EFTA01363029

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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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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

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