EFTA Document EFTA01475244

Subject: ACTION REQUIRED: Issue related to ACUs [I] From: Armen Brash a> Date: Tue, 13 Oct 2015 18:36:40 -0400 To: Paul Morris Amanda Kirby Classification: For internal use only Paul and Amanda, As you may know, per the AML Procedures manual, certain clients are excluded from ACUs. An issue has been identified in dbforce where High Risk clients are given an ACU Auto Exemption for Retail Banking, however, per Policy, this exception does NOT apply to High Risk clients. Unfortunately, th