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efta-efta01370209DOJ Data Set 10Correspondence

EFTA Document EFTA01370209

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DOJ Data Set 10
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efta-efta01370209
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EFTA Disclosure
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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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