Case File
efta-01363152DOJ Data Set 10OtherEFTA01363152
Date
Unknown
Source
DOJ Data Set 10
Reference
efta-01363152
Pages
1
Persons
0
Integrity
Extracted Text (OCR)
Text extracted via OCR from the original document. May contain errors from the scanning process.
If Yes
Money market instruments, i.e. all types of
receivables that are normally traded in the
money market, such as promissory notes
(Schuldschcino) which are tradable on the
money markets and have a residual maturity of
up to 12 months Also, Certificate of Deposits
(CDs) and Commercial Papers (CPS) are usually
money market instruments.
II Yes
Foreign exchange or units of account, including
FX spot (i.e. up to T+2 or as per MiFIRP
II Yes
Derivatives within the meaning of Annex I,
Section C points (4) to (10) of MiFID17
(including options. forwards, caps, floors,
FRAs. futures, swaps, contracts for differences
and credit derivatives)
Note: in order to an instrument to qualify es security or
money market instrument for purposes of GBSA. it must
be tradable/negotiable in the market
If Yes
Financial portfolio management or
investment advice
II Yes
Acting as agent or broker (i.e. not in a principal
capacity)
If Yes
Stakes m a cooperative society within
the meaning of Section I of the
German Cooperative Societies Act
Itienossenschaftsgesetzl
II Yes
If Yes
Commodity spot transactions, but only until
the implementation of MiFID II which is
cutiwaly expected for 3 January 2018.
Physically settled commodity transactions,
unless traded on a regulated market or MTF, or
unless collateralized, or tailless cleared using a
recognized CCP'
If Yes
Order execution or transmission (unless High-
Frequency Trading, see Section 3)
•If this box is marked with lx) please make sure that the lending anti guarantee prohibition in Section 2 will be examined
Q2. If the answer to Q1 is YES: Is the trading activity covered by one or more of the exclusions or exemptions listed in
the table below?
Please indicate YES or NO and describe the basis for this conclusion in the Comments section and by checking the
appropriate box below.
YES (this is permissible trading under GBSA)
NO (this is impermissible proprietary trading under G8SA8
Comments
Mark [X]
Exclusions
It Yes
Market Making
i.e. dealing as a member of a trading venue
(organized market, MU or OTF) a of a market
in a third country, whose legal and supervisory
framework has been declared equivalent by the
European Commission, as pi inc.ipal, in a financial
instrument, on or outside a trading venue, (i) by
posting firm. simultaneous two-way quotes of
comparable size and at competitive prices, with
the result of providing liquidity on a regular and
ongoing basis to the market, as port of the litm's
usual business, (ii) by filtrating orders initiated by
clients or in response to clients' requests to trade
and/or (iii) by hedging positions arising from the
fulfilment of the tasks under fit and en
Mark [X]
Exemptions
if Yes
Hedging of permitted client transactions—
closing of open positions
i.e. transactions to hedge trades with
customers, unless such hedge would relate to
an impermissible loan or guarantee to an AIF
isee below under Section 2)
Anticipatory hedging of future client
transactions is also covered by the exemption.
However, anticipatory hedging does not justify
"warehousing" or holding of an -inventory"
of securities in excess of what is required for
anticipatory hedging.
For internal use only
WM1 ilif),S 025808.070.317
Pane 3ot 11
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0053048
CONFIDENTIAL
SONY GM_00199232
EFTA01363152
Forum Discussions
This document was digitized, indexed, and cross-referenced with 1,400+ persons in the Epstein files. 100% free, ad-free, and independent.
Annotations powered by Hypothesis. Select any text on this page to annotate or highlight it.