EFTA Document EFTA01372920

From: Vijay-A Sawant Sent: 9/11/2018 9:59:49 AM To: Bradley Gillin [-1; Stewart Oldfield CC: Richard larossi [ ]; Mayur Rathod Subject: RE: Assistance Required in Resolving Rejection Points KYC # -- Importance: High Hi Brad, As discussed, following is the excerpt regarding treatment of major donors in Foundation entities as per our latest KOP — For a charity (whether constituted as a trust, foundation, corporation or otherwise), we will regard founding donors contributing more than 25% of the initial funds (more than 10% for high risk) as UBOs. together with significant donors responsible for more than 25% of annual donations — more than 10% for high risk) where we become aware of them. Where the long-standing existence of the charity demonstrates its present wealth not to be reliant on that contributed by a deceased founding donor, then this should be evidenced and documented and the founding donor should not be treated as UBOs. As discussed, this donation was received in 2015, and there have been 2 KYC cases approved since then (2016 & 2017) which did not identify this donor, so we are checking internally on why is this EDR required now? I am waiting for feedback from Daphne and I will get back to once I hear from her on this, thanks. Kind Regards, Vijay Sawant KYC Case Representative Deutsche CIB Centre Private limited - Deutsche Bank Group Wealth Management 81, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway Goregaon East Mumbal 400063, India Tel. Mobile From: Bradley Gillin Sent: Tuesday, September 11, 2018 6:23 PM To: Vijay-A Sawant <[email protected]>; Stewart Oldfield <[email protected]> Cc: Richard larossi <[email protected]>; Mayur Rathod <mayur.rathod db.com> Subject: RE: Assistance Required in Resolving Rejection Points KYC tf - Classification: For Internal use only Hi Vijay. Please send the KYC policy. specifically for a Foundation, regarding below. Thanks Kindly confirm whether this donation constitutes 10% or more of the Gratitude's total assets? Lives, we would require constitutional docs for B1'70, LLC (i.e constitutional docv, formation dots, ownership details. etc) CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0066830 CONFIDENTIAL SDNY_GM_00213014 EFTA01372920