Case File
efta-efta01370209DOJ Data Set 10CorrespondenceEFTA Document EFTA01370209
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DOJ Data Set 10
Reference
efta-efta01370209
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a)
Name
b)
Email address
c)
Telephone number
2.
Please confirm if you are happy for us to contact the above client
directly for KYC documents.
Purpose of Relationship, Business Restrictions & Prohibited
Relationships
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?
Sales Response
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
6.
Does the client engage in business with other areas of DB? (If Yes'
please describe) Include DB division, location and business areas.
Sales Response
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
10.
Based on your existing knowledge of the client what is the Source
of Funds provided? Please answer stating 'A' or 'B'.
A) Ongoing business activities or
B) 'One off event or activities other than normal business activities
Sales Response
11.
Please describe in-detail the activities as described above.
12.
Are funds being received from a party other than the client or a
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
CONFIDENTIAL
DB-SDNY-0062867
SDNY_GM_00209051
EFTA01370209
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