EFTA Document EFTA01372670

Armen Brash Director Deutsche Bank Wealth Management Ikalts4ho Bank Tata Company Anmicas :45 PA* Now Toil., Ni. 10134 Tel: Mo deulscheweAth.con) Sixontica offenatlhau&F0 1 kuBcht: Bank SOCUTiiiCS Inc. From: Armen Brash Sent: Frida , Ma 11, 2018 3:35 PM To: Cc: Janice Franklin ; Diana Canter ; Oliver Esslinger ; Olivier Poncet ; Barry H Morris ; Wayne Salit Yoonsun Chung • ; Prashant Mahendru • ; zia Memon • Anil Tewani Mary C Keaveney ; Derek St- Hilaire Subject: RE: Important Update New Regulation: FinCen CDD Rule Procedures Ill Dawn Forbes ; Kshitij Golani Classification: For Internal use only Everyone, Thank you for your attention to this—there have been a few changes since the original email. I have updated the mydb page (https://mydb.intranet.db.com/docsiDOC-468443) and have included a fully updated version below. In addition to some clerical edits, I want to point out that we have continued to work with AFC on the implementation of this new regulation, and are able to provide some relief on the periodic reviews that were submitted prior to the effective date of the rule. For these KYCs, you may request a temporary exception of up to 60 days to obtain the CDD Form. The exception should be requested through the usual process. In addition to the 60 day temporary exception, AFC has agreed that for these customer only, DB may pre-fill the CDD form based on KYC information. The Form may not be pre-filled for any other customers. To recap, the primary changes are: • The form does not expire after 5 years—it simply must be reconfirmed. • The Delivery Options have been updated/corrected: Note, if the COD Form is received from someone other than the signor, but the signor is cc'd on the email, this is acceptable. The email must be attached to both the KYC and the account opening case. • A 60 Day temporary exception for the CDD form may be requested for all in flight (submitted prior to COB 5/10/2018) KYCs o For these in flight KYCs only, DB may pre-fill the form based on the KYC information on file. o Pre-filling will not be permitted for any other CDD forms. If you have any additional questions, please reach out. CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0066472 CONFIDENTIAL SDNY_GM_00212656 EFTA01372670