EFTA01356558

assigned owners (AFC & ABR). Owners have performed training conununication to staff. stops are being followed by respective teams. Controls Implemented approval clients'accounts. process for the new EEA Implemented reverse solicitation controls at the leadprospect. account. and transaction levels. Implemented controls (checklist) for doimicle eh:Lava into the EEA. EEA Designated Bank= Team KOP Updates Drafted proposal for EEA designated bankers team to be implemented by Sub-GMT heads. All impacted groups. including control groups. have updated procedures. Details on new or amended controls: I Proce.. a. derermi IR' ( USt011IVIN - Detail process toassess EEA client applicability for new clients and changes. for existing clients and update LEA type• EEA country fields in dbForce at the Customer level. Required steps have been outlined and communicated to assigned owners (AFC & ABR). Owners have performed training communication to staff. KOPs have bon updated and steps are being followed by respective teams. • Lead owner: Al3R & AFC • Status: Complete • Attachment: KYC KOPs 2. Recent. Solicitation Controls for new EEA customendacemints(Traioactions: (add description) • Lead owners: s. Norotargd approval owner: Biome'. Stana..a b. Account opening owners: DBOI BR fax I rust. Custody. DPM & Deperob). ABR ending) and Middle Office (Brokerage). c. Transaction owner: B5O d. Domicile changes into the ELI. owner: Business Manager & DEICH • Status: Complete • Attachment: LEA controls summary EEA Designated Bankers Team - Identified proposed controls for KEA designated bankers leant to be implemented for LEA clients. • Lead Owner: Project Team • Status: Complmel (separate implementation SI! lOnig,ne) • Attachment: LEA controls summary I. KOP I •ndates - Update KOPs to reflect new enhanced requirements specific to existing and new EEA chats for Cot crate. ISG'INT, and control groups. • Lead owners: Coverage, ..U3RAFC, Middle Office, BSO, DBO1 and TAO Teams • Status: Complete • .ttlarment: Coverage KOPs. KYC KON. MO EEA KON. 01301 (AOG) EEA KON. BSO EEA KON and I 'ream (I)BOVIlabiore)KOPs. Details on new systemslmaterial system changes (optional • depending on remediationi NA Details on new models/material models changes (optional - depending on remediationt N/A Deviations to original action plans and subsequent communications with external parties No deviations from original action plan. For internal use only Pared 12 Comment (Mgt]: I. Add nets important 511 ref = CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042465 CONFIDENTIAL SDNY_GM_00188649 EFTA01356558