Case File
efta-efta01370210DOJ Data Set 10CorrespondenceEFTA Document EFTA01370210
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DOJ Data Set 10
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group company? If 'Yes', who is the party providing the funds on behalf
of the client and what is the rationale as to why the party does not
establish a relationship in its own name?
13.
Please confirm to the best of your knowledge, are future Source
of Funds known to be different from the Source of Funds at the date of
review? If yes, please provide further detail.
Source of Wealth
Sales Response
14.
Based on your existing knowledge of the client, where an
individual(s) holds > 10% interest, please complete the below. Please
list additional owners, if applicable.
Identify the source of wealth as one or more of the following:
•
Business Owner
•
Salary/Earnings
•
Investment Activity
•
Inheritance
•
Gifts
•
Betting/Lotteries
•
Other (please specify)
For each identified source, describe the activity(ies) which contributed
to the individual's wealth.
Confidentiality & Non-Disclosure Agreements (NDA's) (If applicable)
Sales Response
15.
Are you aware or know of any Confidentiality Agreements or Non-
Disclosure Agreements (NDA's) which prevent the client's data being
shared between DB Locations? (If 'Yes' please describe the
requirements).
Regulatory Status (Level 3 or Level 4 regulated entity)
Sales Response
16.
Are you aware if any changes have been made in the last
12/36/60 months, to your Client's regulatory status or any country or
jurisdiction the Client is connected to? If yes, please provide the name
of the regulator and the regulatory reference number as well as details
of the specific changes.
Politically Exposed Person (PEP) & Adverse Information
Sales Response
17.
To the best of your knowledge are you aware of any new material
adverse information or new PEP relationship linked to the Client and/or
its Connected Parties or affiliates, which could pose a reputational risk
to DB?
If you have any questions please feel free to contact me directly. We may reach out to you if any further information is required.
We will be reaching out to the client for the required documentation, please let me know if you have any concerns with this (see the attached
spreadsheet for more details).
Best Regards,
Michael Valencia
KYC Outreach Analyst
Deutsche Baia - Jacksonville
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0062868
CONFIDENTIAL
SDNY_GM_00209052
EFTA01370210
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