EFTA Document EFTA01356511

From: Sent: To: Subject: Attachments: Location: Start: End: Show Time As: Oliver Esslinger 5/30/2019 11:36:52 AM Ian Salters Hart Funda Bozkurt ; Janice Franklin Managed Exit account handling Managed Exits.xlsx 880884540439, PIN 7303# 6/5/2019 1:00:00 PM 6/5/2019 1:30:00 PM Tentative Recurrence: (none) Bill King ); Kimberly Maria Pedulla ( Term Definition PA Checks/Review Review of client account activity to establish open obligations which prevent onboard A process state for client entities identified for offboarding but have open obligations which prevent process completion The process of sending a client notification to terminate the contractual relationship at the end of a defined notice period The process of closing DB transactional system accounts representing the impacted client entity A count of client entities which have completed all offboarding process stages, and are inactivated through to KYC Records - classified as 'Full' Oftboard when evidenced, complete removal of client entity from all businesses & jurisdictions inclusive of all tech platforms. Applied to all DB adoption entities globally. Managed Exit Notification In Closure Ofiboarded Below is how the CIB process works: • The client is marked to be Off-Boarded but cannot be as there is an outstanding obligation (i.e. loan or position) with the client • Client has been deemed to be KYC relevant by Business • Managed Exit team searches in paid/public sources for the 4 below attributes • Proof of Existence • Legal Representatives • Ownership/IBO • Identity (ID)/Nationality & Source of Wealth (SOW) (Net Worth & source from where it is acquired) • If not found, 2 notification letters are dispatched to the client seeking information • Business is not involved in the sourcing of data • Case is enriched • KYC is collected on a best effort basis and if all 4 attributes cannot be sourced it is notated in the file • Account will be quarantined until the obligation/position expires • ACO signs off on the Managed Exit CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042401 CONFIDENTIAL SDNY_GM_00188585 EFTA01356511