EFTA Document EFTA01363027

Hey — can this be sent downstream now for the GED, GCD, and CB parts? Thanks, Zack From: Martin Zeman Sent: Thursday, M To: James Gladwin Daniel-A Klyashtorny Nina Tona >; Xavier Avila < Davide-A Sferrazza ; AMLUK Reviews t. I ' ; Devshiji Odedra <[email protected]>; Ian Salters Simon Nall < Patel <= a; Jesse-1 Cruz Zack Bunimovich • Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC III 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 <martin.zeman2db.com> Cc: Kareen Johnson <[email protected]>; Daniel-A Klyashtorny <[email protected]>. Nina Tona <[email protected]>; Xavier Avila <xavier.avila(adb.com>; Davide-A Sferrazza [email protected]>; AMLUK Reviews [email protected]>; Devshiji Odedra <[email protected]>; Ian Salters [email protected]>; Simon Nall <[email protected]>; Ricky-x Patel [email protected]>; Jesse-J Cruz <[email protected]>; Zack Bunimovich <[email protected]> Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [Il 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 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; CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0052860 CONFIDENTIAL SDNY_GM_00199044 EFTA01363027