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 support each other. Many thanks all, • imagall igif • James Gladwin AFC Business Advisory Anti-Financial Crime DBOI Global Services (UK) Limited 5 Brindle Place Birmin ham B1 2JB, United Kingdom NA Please consider the environment before printing this email From: James Gladwin Sent: 10 May 2018 09:47 To: Martin Zeman Zack Bunimovich Jesse-J Cruz 11MI II MI Cc: Kareen Johnson S.; Daniel-A Klyashtorny EiMmill >; Nina Tona a; Xavier Avila Davide-A Sferrazza AMLUK Reviews Devshiji Odedra Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 Sout fern cia 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 LRD 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 f will keep you updated on the progress made. Many thanks all, CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0043520 CONFIDENTIAL SDNY_GM_00189704 EFTA01357152