EFTA Document EFTA01399069

Subject: RE: Initial thou hts From: Kimberly Hart Date: Mon, 15 Jul 2019 07:57:16 -0400 To: Wolfram Lange Cc: Michael Off Martina Messing Classification: For internal use only So you are free to speak in 5 minutes? Michael — Are you free? We can use my dial-in: Internal Phone and VC Devices: 88088 4542877; Participant PIN: 972783; External 1 973 631 2000 Internal Phone and VC Devices: 88088 4542877 Participant PIN: 972783 External Audio Participants: Choose country location below for dial-in Then enter number: 88088 4542877 United States +1 Germany United Kingdom Switzerland EFTA01399069 Singapore All global numbers: http://shortcut.db.com/VMRnumbers {https://brandportal.intranet.db.com/img/modules/- DAWN_ logo_ metallic 46x46.gif} Kimberly Hart Managing Director I Divisional Control Officer Wealth Management Americas Deutsche Bank Trust Company Americas 345 Park Avenue, 14th floor, New York, NY 10154 Tel. +1 212 454-2877 Fax +1 646 863-9809 Mobil ea Email Securities offered through Deutsche Bank Securities Inc. From: Wolfram Lange Sent: Monday, July • To: Kimberly Har Cc: Michael Off ; Martina Messing • III > Subject: Re: Initial thoughts It is actually 2pm Frankfurt time, ie CET = Frankfurt Wolfram Lange Managing Director I Divisional Control Officer EFTA01399070 Deutsche Bank Wealth Management The Zig Zag Building, SW1E 6SQ, London, United Kingdom Tel. +44 20 754-59487 Mobile Email On 15 Jul 2019, at 12:06, Kimberly Hart < > wrote: Michael - Does 2pm CET work for you (3pm Frankfurt/9am NY)? If yes, I will send invite. Kimberly Hart Managing Director I Divisional Control Officer Wealth Management Americas Deutsche Bank Trust Company Americas 345 Park Avenue, New York, NY 10154 Tel. +1 212 454-2877 Fax +1 646 863-9809 Mobile +1 Email Securities offered through Deutsche Bank Securities Inc On Jul 15, 2019, at 2:20 AM, Wolfram Lange > wrote: Kim, Michael Looking forward to speaking later today. Early afternoon eg 2pm CET would work best. Here a couple of thoughts - need refinement and challenge... EFTA01399071 Problem statement: Find client cases where we rely on some prior decision and do not question a 'borderline' client relationship - example Epstein where clearance was given again and again despite negative media and other alerts always referring back to Packard/Caruso onboarding decision (even though both had long since left DB). Potential solutions: 1) Assuming that negative media hits and respective clearances are stored: conduct a fuzzy logic search through all clearance statements looking for phrases such as "as per prior approval", " based on decision by", "...". Any hits to be reviewed by DCO/BI/AFC. 2) Search the KYC files for unusually senior sign off parties for onboarding in AFC and the business - come up with a way to electronically search for key words, such as " exception referral", "regional AFC Head", maybe a list of names like prior AFC Heads, Business Heads, COOs. EFTA01399072 Speak later, Wolfram Wolfram Lange Managing Director I Divisional Control Officer Deutsche Bank Wealth Management The Zig Zag Building, SW1E 6SQ, London, United Kingdom Tel. Mobile Email EFTA01399073