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sd-10-EFTA01362904Dept. of JusticeOther

EFTA Document EFTA01362904

From: Sent: To: CC: Nicholas Hislop 5/21/2018 12:07:32 PM Kareen Johnson Simon Nall Martin Zeman Nina Tona AMLUK Reviews ~; Ian Salters Zack Bunimovich Daniel-A Klyashtorny Xavier Avila • Davide-A Sferrazza Devshiji Odedra Ricky-x Patel - ~: Jonathan Whittle James Gladwin Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC ill Classification: For Internal use only Hi Kareen, Jesse-J Cruz Is this not because the client is High risk and therefore

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sd-10-EFTA01362904
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From: Sent: To: CC: Nicholas Hislop 5/21/2018 12:07:32 PM Kareen Johnson Simon Nall Martin Zeman Nina Tona AMLUK Reviews ~; Ian Salters Zack Bunimovich Daniel-A Klyashtorny Xavier Avila • Davide-A Sferrazza Devshiji Odedra Ricky-x Patel - ~: Jonathan Whittle James Gladwin Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC ill Classification: For Internal use only Hi Kareen, Jesse-J Cruz Is this not because the client is High risk and therefore

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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
From: Sent: To: CC: Nicholas Hislop 5/21/2018 12:07:32 PM Kareen Johnson Simon Nall Martin Zeman Nina Tona AMLUK Reviews ~; Ian Salters Zack Bunimovich Daniel-A Klyashtorny Xavier Avila • Davide-A Sferrazza Devshiji Odedra Ricky-x Patel - ~: Jonathan Whittle James Gladwin Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC ill Classification: For Internal use only Hi Kareen, Jesse-J Cruz Is this not because the client is High risk and therefore all extensions are routed to AFC, and/or the Global KYC was out of date? Therefore the completion of the global triggered the local requests for review? From: Kareen Johnson Sent: 21 May 2018 12:34 To: Nicholas Hislop < > Cc: Simon Nall Martin Zeman Daniel-A Klyashtorny , Nina Tona Xavier Avila ., IDavide-A Sferrazza AMLUK Reviews Devshiji Odedra Ian Salters Ricky-x Patel ; Jesse-J Cruz ; Zack Bunimovich • >; Jonathan Whittle James Gladwin ~ fr Subject: Re: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC Good day Nick - We have an issue here where in dbCAR this relationship did not reflect an old GB review date. We can see in the master profile that the relationship was created several years ago under DBAG, but now when extending for a new product, the review was missing completely. The file was escalated to AML for review and approved . This action triggered a GB review date for the very first time. Is it possible this was a merger issue? Please let me know if your team could take a look and if additional information is needed. Thank you! Kareen Johnson On May 18, 2018, at 12:11 PM, James Gladwin wrote: Classification: For internal use only Hi Simon, Absolutely, quite simply: i. Our Jacksonville CDS colleague, Kareen Johnson, will be reaching out to the dbalENT merger team to query the status/success of the KCP merge from dbCLIENT to dbCAR a. @Kareen, it would be great if I could be CC'd in to your correspondence so that AFC can be advised accordingly CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0052589 CONFIDENTIAL SDNY_GM_00198773 EFTA01362904

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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.

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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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; 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

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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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Email From: James Gladwin Sent: 16 May 2018 15:19 To: Martin Zeman Cc: Kareen Johnson A; Daniel-A Klyashtorny < Nina Tona Ulli lia>; Xavier Avila < IMIIIIIMM; Davide-A Sferrazza <=a.; AMLUK Reviews <a; Devshiji Odedra Ian Salters Simon Nall Ricky-x Patel mi ngin; Jessed Cruz < ; ac Bunimovich Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC Ill Classification: For Internal use only Hello all, After liaising with Global CDS teams and specialist col

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