EFTA Document EFTA01401314

Subject: MDs Approvals required for ACUs completed for High Risk clients. [I] From: Vaishali-P Mehta Date: Tue, 31 May 2016 16:52:01 -0400 To: Paul Morris ‹ > Classification: For internal use only Dear Paul, Based on the email I sent last week, below are the ACUs which were completed for your High Risk customers this month. All the below ACUs were completed showing no material changes to the client's circumstances. Please review the ACU comments, and reply back with your approval. Annual Client Update: ID Customer Owner SILO GCIS Customer Number Customer Name Annual Client Update: Created Date A14. A15. Client Status Update Description A16. A17. 0075022 Paul Morris EFTA01401314 US-Onshore 00000409100 Black, Leon D. 5/10/2016 client is CEO of Apollo Global management. Family office established in 2014 to manage family wealth. Distributions from APO and other diversified investments. Yes No 0075020 Paul Morris US-Onshore J. Epstein Virgin Islands Foundation, Inc 5/10/2016 Private foundation investment income Yes No 0075019 Paul Morris US-Onshore Jeepers, Inc 5/10/2016 EFTA01401315 Jeepers is sub S managing various investments investment activities, advisory services Yes No 0075018 Paul Morris US-Onshore Mort, Inc 5/10/2016 Mort is entity holding shares of private company Jawbone Holds private investment No No 0075021 Paul Morris US-Onshore The Haze Trust 5/10/2016 Investment vehicle No change Yes No EFTA01401316 If this any information is not correct or you are aware of a material change that has not been reflected, please let us know immediately as a KYC update will be required. Regards, Vaishali Mehta Head of Anti-Money Laundering Business Risk Deutsche Bank Wealth Management 60 Wall Street, 27th Floor, 10005-2836 New York, NY, USA Tel. Mobil Email fcid:image001.png@OlD030D6.03601EF01 fcid:image002.png@OlD030D6.03601EF01 From: Vaishali-P Mehta Sent: Wednesday, May 25, 2016 4:30 PM To: Armen Brash; Lina M Arias; Sylvia Junghardt; Daphne Cales; Scott Guest; Dawn Forbes; Amy Horak Cc: zia Memon Subject: MDs Approvals required for ACUs completed for High Risk clients. [I] Classification: For internal use only Hello All, As you know, the Bank is taking a very close look at the KYC process in each of the business divisions. At the beginning of the year, several control EFTA01401317 enhancements were rolled out, including ExCo approval for all new high risk account holders. Along these lines, effective immediately, the approval of a Managing Director will be required for all ACUs completed for high risk clients. While we work to implement a workflow within db force, a manual process will begin this month. Each month, I will be sending a list of all ACUs completed for high risk customers to the accountable managing director—in some cases this will be the RM, in some cases this will be the office director. Each accountable managing director will need to review the ACUs completed and reply back with their approval (or rejection, if applicable) ABR will maintain a file of all complete and overdue MD approvals. . The accountable Managing Director will receive an email similar to the one below, including the list of ACUs completed for the client along with the comments contained within the ACU. If you have any questions on this process, please let me know. Sample Email: Dear Below are the ACUs which were completed for your High Risk customers this month. All the below ACUs were completed showing no material changes to the client's circumstances. Please review the ACU comments, and reply back with your approval. EFTA01401318 If this any information is not correct or you are aware of a material change that has not been reflected, please let us know immediately as a KYC update will be required. Armen, Sylvia, Lina, Daphne, Scott and Amy, please share this information with your teams. Regards, Vaishali Mehta Head of Anti-Money Laundering Business Risk Deutsche Bank Wealth Management 60 Wall 005-2836 New York, NY, USA Tel. Mobil Email fcid:image001.png@OlD030D6.03601EF01 fcid:image002.png@OlD030D6.03601EF01 EFTA01401319