EFTA Document EFTA01363028

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. LKYC-US to be reviewed and approved by US colleagues which would subsequently updated the LRD/NRD dates, subsequent leverage could be used off of the LRDs to create an NCA to book the client correctly (US CDS colleagues advised that they did not believe the LKYCUS was to be further actioned) b. LKYC-GB to be approved to kick start the NCA & LRD/NRD dates within dbCAR v. Following the LKYC-GB being approved, the file was immediately reviewed and was deemed that the UK adoption location had been fixed vi. Subsequent Extension request was approved Many thanks to all that shared their knowledge, I will be looking further into KCP clients with UK adoptions to ensure that such scenarios do not become a recurrent theme. As always, please give me a shout if you have any questions. Kind regards, fames Gladwin AFC Business Advisory Anti-Financial Crime DBOI Global Services (UK) Limited 5 Brindle Place, Birmin ham, B12 B, United Kingdom Email: Please r.onsider the environment before !Hinting this email From: James Gladwin Sent: 11 May 2018 18:44 To: Martin Zeman Zack Bunimovich Cc: Kareen Johnson Daniel-A Klyashtorn Xavier Avila eviews Devshiji Odedra Simon Nall Ricky-x Patel Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 Southern Financial LLC Davide-A Sferrazza Classification: For internal use only Hello all, Ian Salters Jesse-J Cruz Nina Tona AMLUK I have had the pleasure with speaking directly with Martin and colleagues to assist UK AFC with this KCP Extension. 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. CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0052861 CONFIDENTIAL SDNY GM_00199045 EFTA01363028