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sd-10-EFTA01363050Dept. of JusticeOther

EFTA Document EFTA01363050

From: Xavier Avila Sent: Monday, April 16 2018 7:44 AM To: Akash Malhotra Cc: Shawn Staker < ; NCAOTC Derivatives ; Pankaj-A Chopra opata ; Nina Tona Ian Salte ; Mathew Negus ; Martin Zeman Subject: RE: KYC Breach_SOUTHF1NANMD_Southem Financial, LLC_FFT Location [I] Negus, what do we do with the below? If easy extension to OTC Rates FFT we can provide docs, if not we move this to London where client is onboarded? Thanks Xavier Avila Managing Director " ies Inc From: Akash Malh

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From: Xavier Avila Sent: Monday, April 16 2018 7:44 AM To: Akash Malhotra Cc: Shawn Staker < ; NCAOTC Derivatives ; Pankaj-A Chopra opata ; Nina Tona Ian Salte ; Mathew Negus ; Martin Zeman Subject: RE: KYC Breach_SOUTHF1NANMD_Southem Financial, LLC_FFT Location [I] Negus, what do we do with the below? If easy extension to OTC Rates FFT we can provide docs, if not we move this to London where client is onboarded? Thanks Xavier Avila Managing Director " ies Inc From: Akash Malh

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From: Xavier Avila Sent: Monday, April 16 2018 7:44 AM To: Akash Malhotra Cc: Shawn Staker < ; NCAOTC Derivatives ; Pankaj-A Chopra opata ; Nina Tona Ian Salte ; Mathew Negus ; Martin Zeman Subject: RE: KYC Breach_SOUTHF1NANMD_Southem Financial, LLC_FFT Location [I] Negus, what do we do with the below? If easy extension to OTC Rates FFT we can provide docs, if not we move this to London where client is onboarded? Thanks Xavier Avila Managing Director " ies Inc From: Akash Malhotra Date: Monday: Apr 16, To: Xavier Avila < Cc: Shawn Staker < Derivatives >, a opa a Subject: KYC Brcach_SOUTHFINANMD_Southcm Financial. LLC_FFT Location III Classification: For Internal use only Hi Alex, Pankaj-A Chopra For adoption location Frankfurt, the following trade has been booked in Summit application for OTC Derivative Product, details as follows: Trade ID: G175714L Summit Code: SOUTHFINANMD Date of Trade: 13/04/2018 Client Name: Southern Financial, LLC We have got your name as a sales person from Summit application. We have observed that the client is not adopted for Frankfurt location, which results in a KYC violation. In order to comply with DB's internal policies and procedures, all KYC requirements now have to be fulfilled, if the trade should stand against Deutsche Bank Kindly review your trade and where possible, please consider to rebook the trade to an adoption location, where the client is already adopted for OTC Derivative product or confirm if it is a valid trade for the particular location. Upon your confirmation, we will review the client and would request the missing documents to be obtained from the client/business as per Frankfurt location guidelines. Summit screenshot: Trade Details Trade 'ape Tra ID Vusion SutTrpe &yarded SHNP I G1757141 5 CCISMAP 13E0412015 Sags Vented Book LAG SLOPS Drupe( Currency Currency par Coral Canary Custorte US:DEUR CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) CONFIDENTIAL DB-SDNY-0052898 SDNY_GM_00199082 EFTA01363050

Related Documents (6)

Dept. of JusticeOtherUnknown

EFTA Document EFTA01406895

Subject: RE: KYC Breach SOUTHFINANMD_Southern Financial, LLC FFT Location [I] From: Mathew Negus 1.11.1.0..M> Date: Tue, 17 Apr 2018 10:44:22 -0400 To: Xavier Avila Nina Tona Cc: Ian Salters < , Martin Zeman Classification: For internal use only Yep Thursday let's catch up. There is a Council call today so I'll get some feedback on system access. This doesn't have the green light yet, GM silo'd so I expect it will be a difficult sell to give WM access to all GM systems. Mathew Negus

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Subject: RE: KYC Breach SOUTHFINANMD Southern Financial, LLC_FFT Location [I] From: Mathew Negus Date: Tue, 17 Apr 2018 09:10:47 -0400 To: Nina Tona Xavier Avila Cc: Ian Salters Martin Zeman Classification: For internal use only Extension to FFT goes to US Case Management. What's the mat date on the xccy swap? Mathew Negus Director I ICG Business Management I I I From: Nina Tona Sent: Tuesday, April 17 2018 8:32 AM To: Mathew Negus Jimmy-H Xu Xavier Avila ; Akash Malhotra Cc:

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Subject: RE: KYC Breach SOUTHFINANMD Southern Financial, LLC_FFT Location [I] From: Xavier Avila Date: Tue, 17 Apr 2018 14:58:46 -0400 To: Mathew Negus Nina Tona Cc: Ian Salters Martin Zeman Daniel-E Kaiser Lets set up call Thursday. It's basic access to booking trades and being able to do our sales job. If we canot do that, I would love to hear what is GM plan B, we go back to relying on ICG to help? That model does mot work anymore (includding because of Project Mercury), we are not

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1 Great Winchester Street, EC2N 2DB London, United Kingdom From: Xavier Avila [mai I io Sent: 16 April 2018 17:55 To: Mathew Ne s Cc: Joe Aglione Pankaj-A Cho r ra Zeman Subject: RE: KYC Breach_SOUTHFINANMD_Southem Financial, LLC_FFT Location [I] Akash Malhotra AOTC Derivatives Nina Tona MO, is it ok to move this trade to London pls? From: Mathew Negus Sent: Monday, April 16, 2018 9:03 AM To: X vi r Avila Cc: Chopra Ian Salters Martin Zeman Subject: RE: KYC Breach_SOUTHFINANMD

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Subject: RE: KYC Breach SOUTHFINANMD_Southern Financial, LLC_FFT Location [I] From: Jimmy-H Xu Date: Mon, 16 Apr To: Xavier Avila Mathew Negus Akash Malhotra < Cc: Joe Aglione Ian Salters Nina Tona Pankaj-A Chopra NCAOTC Derivative Martin Zeman Alka Gopala < Classification: For internal use only Approved as one-off, but let's get the KYC done for FFT please Thanks Kind regards Jimmy {https://brandportal.intranet.db.com/img/modules/logo.gif} Jimmy-H Xu Cross Currency Swap Trad

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EFTA Document EFTA01406842

Subject: RE: KYC Breach_SOUTHFINANMD_Southern Financial, LLC_FFT Location [I] From: Mathew Negus Date: Mon, 16 Apr 2 To: Xavier Avila Akash Malhotra Cc: Shawn Staker NCAOTC Derivatives Pankaj-A Chopra Alka Gopala Nina Tona Ian Salters Martin Zeman Classification: For internal use only I would re-book to London if the desk agrees. From: Xavier Avila Sent: Monday, April 16, 2018 7:44 AM To: Akash Malhotra Cc: Shawn Staker ; NCAOTC Derivatives an aj Chopra Alka • Nina Tona Ia

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