EFTA Document EFTA01399702

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 supposed to be WM, otherwise we become a concierge function with no trading capabilities and with a one off credit trade here and there, it does not work. Alternatively, we build our own world in WM, but whatever it is we need to decide and soon what is our trading operating model cause I need to deliver 100mio PNL and I need the basic infrastructure to achieve that. Xavier Avila Managing Director Deutsche Bank Securities Inc +1 From: Mathew Negus Date: Tuesday, Apr 17, 2018, 09:44 To: Xavier Avila , Nina Tona Cc: Ian Salters , Martin Zeman Subject: RE: KYC Breach_SOUTHFINANMD_Southern Financial, LLC_FFT Location [I] 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. EFTA01399702 Mathew Negus Director I ICG Business Management I I I From: Xavier Avila Sent: Tuesday, April 17, 2018 10:17 AM To: Mathew Negus ; Nina Tona Cc: Ian Salters ; Martin Zeman Subject: RE: KYC Breach_SOUTHFINANMD_Southern Financial, LLC_FFT Location [I] 2028 We will need most of our clients trading XCCY business...so lets see how difficult this is. 03 we suddently stuck with basic DB AG London adoptions. Can we have anoher call rhis thursday to go through some NAC thoughts and also the booking systems pls? Thanks EFTA01399703 From: Mathew Negus Date: Tuesday, Apr 17, 2018, 08:10 To: Nina Tona .a >, Xavier Avila <a> Cc: Ian Salters a, Martin Zeman <a> Subject: RE: KYC Breach_SOUTHFINANMD_Southern Financial, LLC_FFT Location [I] 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 From: Nina Tona Sent: Tuesday, April 17, 2018 8:32 AM To: Mathew Negus Jimmy-H Xu Xavier Avila Akash Malhotra ; Cc: Joe Aglione < Pankaj-A Chopra I I ; Ian Salters a; ; NCAOTC Derivatives ; Martin Zeman a; Alka Gopala Subject: RE: KYC Breach SOUTHFINANMD Southern Financial, LLC_FFT Location [I] EFTA01399704 Classification: For internal use only Mat — let me know if I can help you with this. Thank you Nina Tona KCP products and services are intended and available only for persons who are sophisticated institutional investors within the meaning of the FINRA Rule 4512(C)(3), and who are capable of evaluating the strategies, characteristics and investment risks of, and exercising independent judgment in evaluating, the ideas and products discussed herein. Trades and transactions are subject to relevant internal approvals of DBSI or its affiliates prior to execution, and the execution of any transaction or idea discussed herein is conditional on your becoming a client of Deutsche Bank. Key Client Partners (KCP) products, investment ideas and solutions and related matters discussed herein are provided for discussion purposes only, and strictly on a non-advisory basis. The KCP Americas desk does not provide investment advice. The information set forth herein is confidential and personal to you and is being presented for your information and for discussion purposes only. Any reproduction and/or redistribution thereof (in whole or in part) or disclosure of its content without our written consent is strictly forbidden. This communication does not create any legally binding obligation on the part of DBSI or any of its affiliates. From: Mathew Negus Sent: Tuesday, A ril 17, 2018 7:11 AM To: Jimmy-H Xu ; Xavier Avila Akash Malhotra Cc: Joe A lione < ; Ian Salters Tona ; Pankaj-A Chopra ; Nina ; NCAOTC EFTA01399705 Derivatives ; Martin Zeman <a:•• Alka Gopala Subject: RE: KYC Breach_SOUTHFINANMD_Southern Financial, LLC_FFT Location [I] I'll check who should handle the product extension to FFT. I expect it will be the US team. Jimmy, FYI, I still see mostly London as the primary adoption location for OTC Derivs. Best, Mathew From: Jimmy-H Xu <M > Date: Tuesday, Apr 17, 2018, 2:53 AM To: Xavier Avila , Mathew Ne us Akash Malhotra Cc: Joe A lione Tona Derivatives Alka Gopala S , Ian Salters , Nina , Panka'-A Cho ra , NCAOTC , Martin Zeman Subject: RE: KYC Breach_SOUTHFINANMD_Southern Financial, LLC_FFT Location [I] Classification: For internal use only EFTA01399706 In general, everything should face FFT and other booking centres are only used in exceptional circumstances I believe Thanks Kind regards Jimmy fhttps://brandportal.intranet.db.com/img/modules/logo.gifl Jimmy-H Xu Cross Currency Swap Trading Deutsche Bank AG, CB&S - Markets Winchester House, Tel. Mobile Email Filiale London 1 Great Winchester Street, EC2N 2DB London, United Kingdom From: Xavier Avila Sent: 17 April 2018 02:30 To: Jimmy-H Xu ; Mathew Ne us Akash Malhotra Cc: Joe Aglione ; Ian Salters Tona Chopra Derivatives ; Martin Zeman Alka Gopala Subject: RE: KYC Breach SOUTHFINANMD Southern Financial, ; Nina NCAOTC LLC FFT Location [I] Done, thanks. EFTA01399707 Are all the XCCYs generally booked and clients KYCed in DB AG FFT? What about EUR and GBP vanilla and inflation swaps? We might have some of those coming. Mat/Nina, who can help us with FFT extensions, same NY CMs? Thanks From: Jimmy-H Xu ‹ > Date: Monday, Apr 16, 2018, 11:56 To: Xavier Avila , Mathew Ne us Akash Malhotra C i> , Ian Salters , Nina , Panka'-A Cho ra , NCAOTC , Martin Zeman , Cc: Joe A lione Tona Derivatives Alka Gopala Subject: RE: KYC Breach_SOUTHFINANMD_Southern Financial, LLC_FFT Location [I] Classification: For internal use only Approved as one-off, but let's get the KYC done for FFT please EFTA01399708 Thanks Kind regards Jimmy {https://brandportal.intranet.db.com/img/modules/logo.gif} Jimmy-H Xu Cross Currency Swap Trading Deutsche Bank AG, CB&S - Markets Winchester House, Tel. Mobile Email Filiale London 1 Great Winchester Street, EC2N 2DB London, United Kingdom From: Xavier Avila [mailto: Sent: 16 April 2018 17:55 To: Mathew Negus ; Akash Malhotra Derivatives ; lione ; Ian Salters ; Nina Tona Pankaj-A Chopra NCAOTC , ; Martin Zeman ; • Cc: Joe A Alka Gopala Subject: RE: KYC Breach_SOUTHFINANMD_Southern Financial, LLC_FFT Location [I] Shawn, MO, is it ok to move this trade to London pls? From: Mathew Negus Sent: Monday, April 16, 2018 9:03 AM To: Xavier Avila Cc: Shawn Staker ; Akash Malhotra ; NCAOTC Derivatives ; Pankaj-A Cho ra ; Alka ; Nina Tona -; Ian Salters ; Martin Zeman EFTA01399709 Subject: RE: KYC Breach_SOUTHFINANMD_Southern Financial, LLC_FFT Location [I] 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 ; Pankaj-A Cho ra ; Alka ; Nina Tona ; Ian Salters ; Mathew Negus ; Martin Zeman Subject: RE: KYC Breach_SOUTHFINANMD_Southern 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 Deutsche Bank Securities Inc + 1 From: Akash Malhotra e > Date: Monday, Apr 16, 2018, 07:34 To: Xavier Avila e > EFTA01399710 Cc: Shawn Staker , NCAOTC Derivatives , Pankaj-A Chopra Alka Gopala < Subject: KYC Breach_SOUTHFINANMD_Southern Financial, LLC_FFT Location [I] Classification: For internal use only Hi Alex, 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. EFTA01399711 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 {cid:image001.png@OlD3D561.AD31EA70} Regards Akash Malhotra Associate I Client on Boarding DBOI Global Services Private Limited Global Business Services A-1 & A-2, Evolve - Mahindra Technology Park, Inside Mahindra World City SEZ, 302029 Jai ur, India Tel. Email Escalations Contact:- This communication may contain confidential and/or privileged information. If you are not the intended recipient (or have received this communication in error) please notify the sender immediately and destroy this communication. Any unauthorized copying, disclosure or distribution of the material in this communication is strictly forbidden. Please refer to https://db.com/disclosures for additional EU corporate and regulatory disclosures. Deutsche Bank does not render legal or tax advice, and the information contained in this communication should not be regarded as such. EFTA01399712 EFTA01399713