EFTA Document EFTA01357153

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Unknown

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Dept. of Justice

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sd-10-EFTA01357153

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EFTA Disclosure

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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 [II Classification: For Infernal use only James — responding to your questions below. The extension is permanent. Southern Financial LLC trade global macro and are looking to buy CDX IG payer spreads as a hedge for their overall equities and fixed income portfolio they trade with DB. The initial size is around 5100M. Please call me if you need any more details. This is a priority for our desk. Thank you. From: Zack Bunimovich Sent: Tuesday, May 08, 2018 12:24 PM To: AMLUK Revi James Gladwin Cc: Kareen Johnson Martin Zeman ; Jesse-1 Cruz ; Daniel-A Klyashtorny ; 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 To: AMLUK Reviews James Gladwin Cc: Kareen Johnson Martin Zeman Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC (lJ Jesse-J Cruz Daniel-A KlyashtornMill CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0043521 CONFIDENTIAL SONY GM_00189705 EFTA01357153

Related Documents (6)

Dept. of JusticeOtherUnknown

EFTA Document EFTA01363027

Hey — can this be sent downstream now for the GED, GCD, and CB parts? Thanks, Zack From: Martin Zeman Sent: Thursday, M To: James Gladwin Daniel-A Klyashtorny Nina Tona >; Xavier Avila < Davide-A Sferrazza ; AMLUK Reviews t. I ' ; Devshiji Odedra <ckvshikodedra@ib.com>; Ian Salters Simon Nall < Patel <= a; Jesse-1 Cruz Zack Bunimovich • Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC III Classification: For Internal Use only James, thank you.

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 EFTA01357150

; Zack Bunimovich u ject: : sca atton: ONB-1135648 / LKYCGB-160049 / Southern Financial Ut III Classification: For intemal use only James Thank you for the update Can you confirm the plan for the feedback on 3A below Kind Regards Simon Nall <image001.gif> Deutsche Bank Email From: James Gladwin Sent: 16 May 2018 15:19 To: Martin Zeman Cc: Kareen Johnson ; Daniel-A Klyashtorny Nina Tona ~111~-; Xavier Avila Davide-A Sferrazza AMLUK Reviews >; Devshiji Odedra a; lan Sal

Dept. of JusticeOtherUnknown

EFTA Document EFTA01357165

Reviews Devshiji Odedrj . Subject: RE: Escalation: ONB-l outhern Financial LLC Ill Classification: For In use only Hello all, Do we have BRG approval for this? This is appears to be a cross-jurisdictional adoption from 0BSI 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. T

Dept. of JusticeOtherUnknown

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 EFTA01400111

Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 LLC [I] From: Nina Tona < Date: Wed, 16 May 2018 10:59:10 -0400 To: Simon Nall James Gladwin Martin Zeman Kareen Johnson Daniel-A Klyashtorn Xavier Avila Davide-A Sferrazza AMLUK Reviews Devshiji Odedra Ian Salters Ricky-x Patel Jesse-J Cruz Zack Bunimovich >, • Cc: • • Classification: For internal use only • • • / Southern Financial Kareen — can you please advise where we stand with this client? Thank you Nina Tona

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