Case File
efta-01365175DOJ Data Set 10OtherEFTA01365175
Date
Unknown
Source
DOJ Data Set 10
Reference
efta-01365175
Pages
1
Persons
0
Integrity
Extracted Text (OCR)
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Purpns• of Relationship, Business Restrictions & Prohibited
Relationships
Sales Response
3.
Describe the Purpose of Relationship in respect to the
products / activities / services used by the client. Do the DB products
used by the client make sense, considering the nature of their business
and investment profile? e.g.: Is the client a guarantor?
4.
Do any Business Restrictions apply to the client relationship?
(If 'Yes' please describe)
For example, restrictions on trading certain products, types of
transactions, or transacting for a specific period of time.
5.
Does the client present any prohibited business factors? (if
'Yes' please describe) Examples may include anonymous accounts, shell
banks or Pay-through accounts, certain business activities in Special Risk
Countries - SRC).
Nature of Relationship
Sales Response
6.
Does the client engage in business with other areas of DB? (If
'yes' please describe) Include DB division, location and business areas.
7.
If known, how was the relationship originally established?
Choose one:
•
Intermediary-agent (please detail)
•
DB group referral
•
Targeted business
•
Unsolicited
approach
by
client
(including
non-DB
referrals/introducers).
8.
What was the client's rationale for establishing the
relationship? Why did the client open their account with DB?
Bearer Shares
Sales Response
9.
Are you aware if the client, or any entity in the client's
ownership chain, currently has the ability to issue Bearer Shares?
•
The latest version of the M&A document(s) will state whether
the entity has the ability to issue bearer shares. Only certain countries
have laws that permit the use of Bearer shares. e.g: BVI, Bahamas,
Cayman Islands, Panama, Switzerland. There is No requirement to
explicitly confirm with the Legal Entity that it has issued Bearer Shares.
However in the course of establishing the ownership structure and
identifying UBOs the presence of Bearer Shares may be identified.
Source of Funds & Future Source of Funds
Sales Response
10.
Based on your existing knowledge of the client what is the
Source
of
Funds
provided?
Please
answer
stating
'A'
or
A) Ongoing business activities or
B) 'One off event or activities other than normal business activities
11.
Please describe in-detail the activities as described above.
12.
Are funds being received from a party other than the client or
a group company? If 'Yes', who is the party providing the funds on
behalf of the client and what is the rationale as to why the party does
not establish a relationship in its own name?
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
CONFIDENTIAL
DB-SDNY-0055843
SDNY_GM_00202027
EFTA01365175
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