EFTA Document EFTA01368139

US Risk Assessment Risk Assessment Is the entity registered or domiciled in a Level 1,2,3.4 Country. 2 Is the entity involved in a hqh risk industry? No Is a UBO of the entity a national of a Level 4 country and/or domiciled in a Level 4 country? No If a natural person facing DB as a direct client - are they a PEP (determined from PCR or any other source)? N/A Is a UBO of the entity a PEP? No Is a legal representative (control person) of the entity a PEP (determined from PCR or any other source)? No Is 10% or greater of the ownership held in bearer form? (not applicable if the bearer shares are traded on a CB&S and GIB Recognised Exchange) No To your knowledge, are you aware of any material negative information (from PCR or any other source) about the entity, and/or its UBO's and Legal No Representatives. which could pose a reputational risk to DB? If DB are facing a Collective Investment Scheme (Both open-ended and closed end funds) - does a natural person own greater than 25% of the N/A investment (directly or indirectly) in the CIS? Is the entity a Private Investment Vehicle i.e. a private investment company. foundation or trust set up for/on behalf of a high net worth Yes individual(s)/family? Is the entity that is being onboarded. contractually engaged by DB to develop investment business relationships or to introduce / procure business No transactions e.g. a business finder / arranger / introducer / consultant / intermediary etc? Have you come across any other reason for escalation to AML Compliance? No Is an account being opened for a foreign financial institution' eFFII) registered and/or domiciled in either a Level 3 or 4 Country ? • Foreign financial institutions as defined within Section 312 of the USA PATRIOT Ad are Non-U.S banks, broker dealers. futures commission merchants, Introducing No brokers in commodities. mutual funds. money transmitters or currency exchangers and private banking accounts Total Risk: High Override Risk Rating Override Risk Rating ?Overriding Risk Rating is to be in exceptional circumstances only. It should not be as a substitute for answenng the KYC questions No correctly to derive the appropriate Risk Rating. Override KYC Next Review Date Override KYC Next Review Date ?Overriding KYC Next Review Date is to be used in exceptional circumstances only. It should not be used as a substitute No for answering the KYC questions correctly to derive the appropriate KYC Next Review Date. Page 12 CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0059800 CONFIDENTIAL SDNY_GM_00205984 EFTA01368139