EFTA01406921

Subject: RE: Escalation: / Southern Financial LLC [I] From: Zack Bunimovich Date: Fri, 18 Ma 2018 13:15:09 -0400 To: Nina Tona ODC-Equities Account-Openin Jesse-J Cruz Cc: ODC FixedlncomeRepoECM Martin Zeman Classification: For internal use only Hi Nina, I believe James was speaking about the AFC review for the account. Now that the AFC piece was approved, the account was able to move forward to the downstream operational setups. This is essentially the last part in the process. The ask is for some sort of confirmation details to use for margining with Southern. Attaching the original ask here. Thanks, Zack From: Nina Tona Sent: Friday, May 18 2018 1:02 PM To: Zack Bunimovich Cc: ODC FixedlncomeRe oECM Subject: RE: Esca ation: LLC [I] ; ODC-Equities Account-0 Jesse-3 Cruz Classification: For internal use only Martin Zeman / Southern Financial Zack — can you please clarify the ask? EFTA01406921 I thought James said this was completed? Thank you Nina Tona KCP products and services are intended and available only for persons who are sophisticated institutional investors within the meaning of the FINRA Rule 4512(C)(3), and who are capable of evaluating the strategies, characteristics and investment risks of, and exercising independent judgment in evaluating, the ideas and products discussed herein. Trades and transactions are subject to relevant internal approvals of DBSI or its affiliates prior to execution, and the execution of any transaction or idea discussed herein is conditional on your becoming a client of Deutsche Bank. Key Client Partners (KCP) products, investment ideas and solutions and related matters discussed herein are provided for discussion purposes only, and strictly on a non-advisory basis. The KCP Americas desk does not provide investment advice. The information set forth herein is confidential and personal to you and is being presented for your information and for discussion purposes only. Any reproduction and/or redistribution thereof (in whole or in part) or disclosure of its content without our written consent is strictly forbidden. This communication does not create any legally binding obligation on the part of DBSI or any of its affiliates. From: Zack Bunimovich Sent: Friday, May 18, 2018 12:49 PM To: ODC-Equities Account-0 enin Jesse-J Cruz oECM Nina Tona Subject: RE: Escalation: LLC [I] Martin Zeman / Southern Financial EFTA01406922 Classification: For internal use only Adding Nina in case Martin is 000. Thanks, Zack From: Zack Bunimovich Sent: Thursday, May 17, 2018 3:45 To: ODC-Equities Account-0 enin Jesse-J Cruz Cc: ODC FixedlncomeRe oECM Subject: RE: Escalation: LLC [I] Classification: For internal use only Martin Zeman / Southern Financial Hey Martin — do you have any confirmation details that can be used for downstream setups? See attached for the request. Maybe we can use Richard's email? Thanks, Zack From: Nikita Bajaj On Behalf Of ODC-Equities Account-Opening Sent: Thursday, May 17, 2018 1:39 PM To: Jesse-J Cruz Cc: Zack Bunimovich ; ODC-Equities Account-Opening EFTA01406923 ; ODC FixedlncomeRepoECM Subject: RE: Escalation: LLC [I] Classification: For internal use only Hi Jesse, / / Southern Financial We are awaiting for the confirmation email. Please find attachment for your reference. Thanks and Regards, Nikita. Client Account Management GTO Tel: Group Inbox : ODC-Equities. Account ODC-Equities Account Please reply to above emails for quick response. Feedback / Escalations: ESCALATION Points of contact APAC Coverage EMEA Coverage Late EMEA / NY Coverage Level-1 EFTA01406924 Devaraj Vaddin Leroy Coutinho Mukesh-tcs Shah Level-2 Bharath Achar Vritika Mutreja Rajesh-E Kumar Level-3 Gourish Shirodkhar Kiran-Chandrakant Naik Chaitanya Nataraj EFTA01406925 This email is sent to you by Tata Consultancy Services on behalf of Deutsche Bzank. Diese email wurde Ihnen von Tata Consultancy Services im Auftrag der Deutschen Bank gesendet From: Jesse-3 Cruz Sent: 17 May 2018 22:22 To: ODC-Equities Account-Opening FixedlncomeRepoECM Cc: Zack Bunimovich Subject: RE: Escalation: Southern Financial LLC [I] ODC Classification: For internal use only Hi Teams, Please set up for GED and Convertible Bonds. Kind regards, {cid:[email protected]} Jesse Jay Cruz Analyst EFTA01406926 Deutsche Bank Securities Inc. Client Data Services I DBUSA Core Corp. 5201 Gate Parkway, 32256 Jacksonville, USA Tel: Email: From: Zack Bunimovich Sent: Thursday, Ma 17 2018 12:17 PM To: Jesse-3 Cruz Subject: RE: Escalation: LLC [I] Classification: For internal use only Southern Financial Hey — can this be sent downstream now for the GED, GCD, and CB parts? Thanks, Zack From: Martin Zeman Sent: Thursday, May 17, 2018 11:44 AM To: James Gladwin Cc: Kareen Johnson Daniel-A Klyashtorny • Nina Tona • Xavier Avila Davide-A Sferrazza • AMLUK Reviews ; Devshiji Odedra Ian Salters Simon Nall Ricky-x Patel Jesse-3 Cruz Zack Bunimovich EFTA01406927 Subject: RE: Escalation: Southern Financial LLC [I] Classification: For internal use only James, thank you. Zach — please let us know next steps and timing to complete this extension for Southern Financial LLC. Martin From: James Gladwin Sent: Wednesday, May 16, 2018 10:19 AM To: Martin Zeman Cc: Kareen Johnson Daniel-A Klyashtorny • Nina Tona • Xavier Avila Davide-A Sferrazza • AMLUK Reviews ; Devshiji Odedra Ian Salters Simon Nall Ricky-x Patel ; Jesse-3 Cruz • Zack Bunimovich Subject: RE: Escalation: Southern Financial LLC [I] Classification: For internal use only Hello all, After liaising with Global CDS teams and specialist colleagues, UK AFC have identified the key barriers and now duly approved the Extension request. I am happy to confirm that a BRG approval will NOT be necessary for this EFTA01406928 Extension. For the sake of clarity and knowledge sharing it would be prudent to share a brief summary of the cause and resolution of such. I am more than happy to discuss and expand further via telephony should it be requested. i. Extension request was received by UK AFC and upon our initial review of the request it was apparent that there was no UK adoption within the dbCAR system, therefore AFC queried the requirement of a BRG review ii. Post investigation identified UK products had been booked WITHOUT a UK adoption — a never seen before scenario iii. Escalations to local policy colleagues and global CDS teams had also never seen such a scenario. Two cause theories were presented; a. KCP clients had migrated from dbCLIENT to dbCAR, potentially the migration did not complete correctly (this will continue to be investigated SEPERATELY to this Extension request) b. At the very first adoption of the client/extension to UK GM products, this was not correctly booked within our internal systems iv. Fixes to the dbCAR profile were discussed between Global CDS teams, of which the latter was chosen due to time constraints and the impact upon our first line colleagues ; a. LKYC-US to be reviewed and approved by US colleagues which would subsequently updated the LRD/NRD dates, subsequent leverage could be used off of the LRDs to create an NCA to book the client correctly (US CDS colleagues advised that they did not believe the LKYCUS was to be further actioned) b. LKYC-GB to be approved to kick start the NCA & LRD/NRD dates within dbCAR v. Following the LKYC-GB being approved, the file was immediately reviewed and was deemed that the UK adoption location had been fixed vi. Subsequent Extension request was approved Many thanks to all that shared their knowledge, I will be looking further into KCP clients with UK adoptions to ensure that such scenarios do not EFTA01406929 become a recurrent theme. As always, please give me a shout if you have any questions. Kind regards, {logo} James Gladwin AFC Business Advisory Anti-Financial Crime DBOI Global Services (UK) Limited 5 Brindley Place, Birmingham, B1 2JB, United Kingdom Email: P Please consider the environment before printing this email From: James Gladwin Sent: 11 May 2018 18:44 To: Martin Zeman Jesse-J Cruz Cc: Kareen Johnson Nina Tona ; Davide-A errazza Reviews Devshiji I.e.ra Ian Salters ; Simon Nall Patel Subject: RE: Escalation: LLC [I] Zack Bunimovich ; Daniel-A Klyashtorny • Xavier Avila ; AMLUK •ic y-x Southern Financial EFTA01406930 Classification: For internal use only Hello all, I have had the pleasure with speaking directly with Martin and colleagues to assist UK AFC with this KCP Extension. UK AFC are kindly in receipt of the KCP GM policy dated June 2017 (duly noted that this is currently under review), this document has proved useful in giving context to the UK GM product nexus with solely a US booking. Due to the local UK time, I will be discussing KCP Extensions with my management on Monday as to best understand and process such requests in the future. I truly appreciate the time and knowledge that has been shared and look forward to our conversations next week as to support each other. Many thanks all, {logo} James Gladwin AFC Business Advisory Anti-Financial Crime DBOI Global Services (UK) Limited 5 Brindley Place, Birmingham, B1 2JB, United Kingdom Email: P Please consider the environment before printing this email EFTA01406931 From: James Gladwin Sent: 10 May 2018 09:47 To: Martin Zeman Jesse-J Cruz Cc: Kareen Johnson Daniel-A Klyashtorny ; Xavier Avila Zack Bunimovich • Nina Tona Davide-A Sferrazza Reviews ; Devshiji Odedra Subject: RE: Escalation: LLC [I] Classification: For internal use only Hello all, Do we have BRG approval for this? ; AMLUK Southern Financial This is appears to be a cross-jurisdictional adoption from DBSI to DB AG, furthermore, the LRD for the US is 2016 and does not appear to be in the Remediation pipeline? For Extensions to be approved, AFC UK require: i. BRG approval to consider cross-jurisdictional approvals which result in newly booked High Risk clients ii. The file to be within NRD date and if not, must be within the Remediation pipeline — of which it appears it is neither @CDS colleagues, Please consider the above points, I am happy to further explain on the phone to assist our business colleagues & clients expectations. @Martin I will keep you updated on the progress made. EFTA01406932 Many thanks all, {logo} James Gladwin AFC Business Advisory Anti-Financial Crime DBOI Global Services (UK) Limited 5 Brindley Place, Birmingham, B1 2JB, United Kingdom Email: P Please consider the environment before printing this email From: Martin Zeman Sent: 08 May 2018 20:27 To: Zack Bunimovich AMLUK Reviews ; Jesse-J Cruz ; James Gladwin Cc: Kareen Johnson IIIMP. Nina Tona • Davide-A Sferrazza u ject: : sca a ion: LLC [I] Classification: For internal use only • Daniel-A Klyashtorny • Xavier Avila Southern Financial James — responding to your questions below. The extension is permanent. Southern Financial LLC trade global macro and are looking to buy CDX IG payer spreads as a hedge for their overall equities and fixed income portfolio they trade with DB. The initial size is around $100M. EFTA01406933 Please call me if you need any more details. This is a priority for our desk. Thank you. From: Zack Bunimovich Sent: Tuesday, May 08, 2018 12:24 PM To: AMLUK Reviews ; James Gladwin c: areen o nson ; Jesse-J Cruz ; Daniel-A Klyashtorny ; Martin Zeman • Nina Tona Subject: RE: Escalation: Southern Financial LLC [I] Classification: For internal use only +Nina From: Zack Bunimovich Sent: Tuesday, May 08, 2018 10:21 AM To: AMLUK Reviews •IIMEM IE; Jesse-3 Cruz ; James Gladwin Daniel-A Klyashtorny Martin Zeman Subject: RE: Escalation: LLC [I] Classification: For internal use only Hi James, Southern Financial For ii, this is a permanent extension. EFTA01406934 Martin — can you advise on the questions from James in i. below? Thanks, Zack From: James Gladwin On Behalf Of AMLUK Reviews Sent: Tuesday, May 08, 2018 10:18 AM To: Jesse-3 Cruz James Gladwin Cc: Kareen Johnson ; Daniel-A K yas torny ; Zack Bunimovich ; AMLUK Reviews Subject: RE: Escalation: LLC [I] Classification: For internal use only Hi both, I am happy to help. Southern Financial Just a couple of immediate questions to help expedite this: i. a. ii. a. What is the business purpose for the extension? Elaborate on key details including; booked trades, expected volumes Is the extension request permanent or temporary? Please provide activation/closure dates if temporary FYI, Helen has been removed from the chain as she has left the bank. AMLUK.COMPLIANCE has been removed, AMLUK.REVIEWS primarily EFTA01406935 work extensions/reactivations now alongside our PRs/EDRs and not the aforementioned team. Many thanks! {logo} James Gladwin AFC Business Advisory Anti-Financial Crime DBOI Global Services (UK) Limited 5 Brindley Place, Birmingham, B1 23B, United Kingdom Email: P Please consider the environment before printing this email From: Jesse-3 Cruz Sent: 08 May 2018 15:06 To: AMLUK Reviews ; James Gladwin Cc: Kareen Johnson LLC [I] Classification: For internal use only James/Helen, amluk compliance ; Helen Ncube ; Daniel-A Klyashtorny Southern Financial EFTA01406936 Can you assist with this request? Please make top priority. Thanks, Jesse From: Zack Bunimovich Sent: Monday, May 07, 2018 3:51 PM To: Jesse-3 Cruz amluk com Cc: Kareen Johnson Daniel-A Klyashtorny Subject: RE: Escalation: Southern Financial LLC [I] Classification: For internal use only Classification: For internal use only Hi AML teams, Can you please revert on the below? Thanks, Zack From: Jesse-J Cruz Sent: Thursday, May 03, 2018 3:05 PM To: AMLUK Reviews Cc: Zack Bunimovich Subject: Escalation: amluk compliance Kareen Johnson Southern Financial LLC [I] EFTA01406937 Classification: For internal use only Hi All, We are performing a principal product extension for Southern Financial, LLC for GED, Convertible Bonds, and Global Credit Derivatives in DBAG. DBcar triggered a high risk rating. Attached is an EDD package comprised of the following: Searches Formation documents Tax document Correspondence with client emails Financial statements Please let me know if you need any additional information. Kind regards, {cid:[email protected]} Jesse Jay Cruz Analyst Deutsche Bank Securities Inc. Client Data Services I DBUSA Core Corp. 5201 Gate Parkway, 32256 Jacksonville, USA EFTA01406938 Tel: Email: EFTA01406939