EFTA Document EFTA01370242
Deutsche Bank Compliance / RECOMMENDATION The Dormant account rule cannot restrict specific transaction types (i.e. low risk transactions like internal transfers) to be excluded from the process. So, a weighted methodology for weekly/monthly sampling based on underlying transactions and risk class has been established. No new recommendations. http:/ db.comll 21 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0062906 CONFIDENTIAL SDNY_GM_00209090 EFTA01370242
Summary
Deutsche Bank Compliance / RECOMMENDATION The Dormant account rule cannot restrict specific transaction types (i.e. low risk transactions like internal transfers) to be excluded from the process. So, a weighted methodology for weekly/monthly sampling based on underlying transactions and risk class has been established. No new recommendations. http:/ db.comll 21 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0062906 CONFIDENTIAL SDNY_GM_00209090 EFTA01370242
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