Case File
efta-01363157DOJ Data Set 10OtherEFTA01363157
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DOJ Data Set 10
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efta-01363157
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Section 3: High-Frequency Trading Prohibitions
This section addresses high-lierruency trading activities of Deutr:che Bank Group in financial instruments.
Level 1
01. Does the activity relate to some form of electronic or algorithmic trading of financial instruments within the meaning
of GBSA? (See Table under 01 of Section 1 for examples of financial instruments)
YES (if the answer is "yes-, please proceed to 02)
NO (ii the answer is "no-, this transaction is ant prohdfiterl Ifigh-Frequency Trading under GBSA)
02. Does the activity relate to a German trading venue?
A "German trading venue" is an exthange, MTF or OTF operated in Germany or by a German market operator.
• YES (if the answer is "yes-, please proceed to 03)
NO (if the answer is "no". this transaction is not prohibited High-Frequency Trading uncle, USA)
03. Has Global Technology affirmed in writing that the technical system which is used for the execution of the trades
does not qualify as a high-frequency algorithmic trading technique within the meaning of Section 1(1a) sent. 2 no. 4d of
the German Banking Act?' Please attach the affirmation from GTO.
YES fit the answer is "yes". this transaction is not prohibited High-Frequency Trading under GBSA)
NO
the answer is "no". please contact the Walt for further review.)
I attest that the above information is accurate and current:
Cynthia Rodriguez
Name of ficlanniqu
•
•
win Specialist
Signatuw of Beta
up Managmtkrins
a Spnpinast
07/17/2017
(Mu
5 Needs to be reviewed once Mir•1D II is implemented in German Banking Act i e.. second FiMalloG passes German parliament
(Contact information to be inserted.)
High-frequency algorithmic trading technique is characterised by (i) the use of infrastructure intended to minimise latency,
particularly co-location, proximity hosting or high. speed direct electronic: market access; (ii) system determination of
order initiation, generating, routing or execution without human intervention: and Old high message intra- day rates which
constitute orders, quotes or cancellations. When assessing these requirements. GTO shall take into account the further
details as described in BaFin's Frequently asked questions (FAOs) eelatiiw, in the High-Frequency
TradingAct(https://www.tedin.de/SharedDocs/Downloads/EN/FAOhilfathfr_en.pdf, _blob=publicationFile&wr
B IContact information to be inserted.)
P 2017 Deutsche Bank AG. A9 rights Si Rrnlived WIN IMPS 025a0B.070.)I7
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0053056
CONFIDENTIAL
SONY GM_00199240
EFTA01363157
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