EFTA Document EFTA01475271

Subject: RE: ACTION REQUIRED: Issue related to ACUs [I] From: Jj Litchford ‹ > Date: Thu, 15 Oct 2015 14:43:20 -0400 To: Amanda Kirby Armen Brash Paul Morris Classification: For internal use only These have been completed, thanks Armen. fcid:image001.gif@OlD02B3A.F8AC3FC01 JJ Litchford Associate Banker Deutsche Bank Trust Company Americas Deutsche Asset & Wealth Management 345 Park Avenue, 24th Floor New York, New York 10154 Tel. Mobile Email {cid:image002.gif@OlD02B3A.F8AC3FC0} From: Amanda Kirby Sent: Tuesday, October 13, 2015 7:08 PM To: Armen Brash; Paul Morris; Jj Litchford Subject: Re: ACTION REQUIRED: Issue related to ACUs [I] Classification: For Internal Use Only Ill work with JJ on these EFTA01475271 From: Armen Brash Sent: Tuesday, October 13, 2015 06:36 PM To: Paul Morris; Amanda Kirby Subject: ACTION REQUIRED: Issue related to ACUs [I] 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, the code in dbforce exempting high risk clients with only deposit accounts under $250K from the ACU when it should not be—the code will be fixed ASAP, but in the meanwhile, while the ACUs listed below don't appear as overdue, they must be completed by year end. Customer Name Customer # Relationship Primary Officer ACU Completed Date Butterfly Trust SOUTHERN FINANCIAL RELATIONSHIP Paul Morris EFTA01475272 The 2007 Jeffrey E. Epstein Insurance Trust #3 SOUTHERN FINANCIAL RELATIONSHIP Paul Morris New York Strategy Group, LLC SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Plan D, LLC SOUTHERN FINANCIAL RELATIONSHIP Paul Morris HBRK Associates, Inc SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Hyperion Air, LLC SOUTHERN FINANCIAL RELATIONSHIP EFTA01475273 Paul Morris JEGE, Inc SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Neptune, LLC SOUTHERN FINANCIAL RELATIONSHIP Paul Morris SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Zorro Development Corp. SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Gratitude America EFTA01475274 SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Please let me know if you have any questions and please let me know when this has been completed. Best, Armen fcid:image001.gif@OlD10757.D55212D01 Armen Brash Director Deutsche Asset & Wealth Management 345 Park Avenue, 10154-0004 New York, NY, USA Tel. Fax Mobile Email fcid:image002.gif@OlD10757.D55212D01 EFTA01475275