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efta-01378690DOJ Data Set 10OtherEFTA01378690
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DOJ Data Set 10
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efta-01378690
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>; Daphne Cales <
Subject: 2018 KYC Case Manager III
Classification: For Internal use only
Hi Vijay
In line with the 2018 KYC Target Operation Model, you are being assigned to take on the role of KYC case manager
supporting Tern and her team
I have attached a list of the customers that are in scope for KYC in 2018.
As case manager, you are responsible for managing and driving the completion of KYCs , working with the banking team,
by the due date defined in the attached (column M in the spreadsheet); ultimate ownership over the KYC remains with
the Banker. I have listed key activities below which will require liaising with the banking team, Client On-Boarding and
the Research team in Jaipur.
Please note that for those customers where the comments in column P indicate an account is closing / closed, or
exclude please confirm with the Tern and her team as a KYC will not need to be performed if closing.
•
Paper KYC: Entry of KYC information (from Paper File); prior KYC was performed prior to digitization.
•
Case Preparation: Initial KYC updates (already in KYC format) or Enter information in KYC format (if there is not a
prior KYC).
•
Good Standing Certificate: US Entity — Look on the Secretary of State website; Non US Entity
•
Source of Wealth: Document SOW (info obtained from On-line, the client, legal docs, etc.). Provide Summary to
Banker / RC to review
•
Google Search: Perform a google search on Account Holders and UBOs.
•
Due Diligence / Research: PEP, Lexus/Nexus / Negative news (Systems/ DBs used: PCR, RDC, BIS). — submit
requests to the Jaipur team and perform initial review of results (Central Mailbox PWM BIS-Research I=
•
Update KYC: Update existing KYC (e.g. when % ownership changes, new signers, etc.)
•
Questionnaires: Complete GBSA and Volker Questionnaires. — Liaise with Client on-boarding who complete the
questionnaire (Central Mailbox
Refer to email attachment.
Please reach out with any questions
Kind Regards
Adrienne
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
M-SDNY-0075921
SDNY_GM_00222105
CONFIDENTIAL
EFTA01378690
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