EFTA Document EFTA01400111

Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 LLC [I] From: Nina Tona < Date: Wed, 16 May 2018 10:59:10 -0400 To: Simon Nall James Gladwin Martin Zeman Kareen Johnson Daniel-A Klyashtorn Xavier Avila Davide-A Sferrazza AMLUK Reviews Devshiji Odedra Ian Salters Ricky-x Patel Jesse-J Cruz Zack Bunimovich >, • Cc: • • Classification: For internal use only • • • / Southern Financial Kareen — can you please advise where we stand with this client? Thank you Nina Tona KCP products and services are intended and available only for persons who are sophisticated institutional investors within the meaning of the FINRA Rule 4512(C)(3), and who are capable of evaluating the strategies, characteristics and investment risks of, and exercising independent judgment in evaluating, the ideas and products discussed herein. Trades and transactions are subject to relevant internal approvals of DBSI or its affiliates prior to execution, and the execution of any transaction or idea discussed herein is conditional on your becoming a client of Deutsche Bank. Key Client Partners (KCP) products, investment ideas and solutions and related matters discussed herein are provided for discussion purposes only, and strictly on a non-advisory basis. The KCP Americas desk does not provide investment advice. EFTA01400111 The information set forth herein is confidential and personal to you and is being presented for your information and for discussion purposes only. Any reproduction and/or redistribution thereof (in whole or in part) or disclosure of its content without our written consent is strictly forbidden. This communication does not create any legally binding obligation on the part of DBSI or any of its affiliates. From: Simon Nall Sent: Wednesday, Ma 16, 2018 10:26 AM To: James Gladwin Cc: Kareen Johnson < ; Nina Tona ; Davide-A Sferrazza Reviews ; Devshiji Odedra Ian Salters ; Ricky-x Patel Jesse-J Cruz ; Zack Bunimovich Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] Classification: For internal use only James Thank you for the update >; Martin Zeman ; Daniel-A Klyashtorny <daniel- ; Xavier Avila ; AMLUK Can you confirm the plan for the feedback on 3A below Kind Regards Simon Nall TEL — {logo} EFTA01400112 Deutsche Bank Email From: James Gladwin Sent: 16 May 2018 15:19 To: Martin Zeman Cc: Kareen Johnson ; Daniel-A Klyashtorny <daniel- Nina Tona ; Xavier Avila Davide-A Sferrazza -; AMLUK Reviews Ian Salters Patel Bunimovich Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] ; Devshiji Odedra ; Simon Nall ; Ricky-x >; Jesse-J Cruz ; Zack Classification: For internal use only Hello all, After liaising with Global CDS teams and specialist colleagues, UK AFC have identified the key barriers and now duly approved the Extension request. I am happy to confirm that a BRG approval will NOT be necessary for this Extension. For the sake of clarity and knowledge sharing it would be prudent to share a brief summary of the cause and resolution of such. I am more than happy to discuss and expand further via telephony should it be requested. i. Extension request was received by UK AFC and upon our initial review of the request it was apparent that there was no UK adoption within the dbCAR system, therefore AFC queried the requirement of a EFTA01400113 BRG review ii. Post investigation identified UK products had been booked WITHOUT a UK adoption — a never seen before scenario iii. Escalations to local policy colleagues and global CDS teams had also never seen such a scenario. Two cause theories were presented; a. KCP clients had migrated from dbCLIENT to dbCAR, potentially the migration did not complete correctly (this will continue to be investigated SEPERATELY to this Extension request) b. At the very first adoption of the client/extension to UK GM products, this was not correctly booked within our internal systems iv. Fixes to the dbCAR profile were discussed between Global CDS teams, of which the latter was chosen due to time constraints and the impact upon our first line colleagues ; a. LKYC-US to be reviewed and approved by US colleagues which would subsequently updated the LRD/NRD dates, subsequent leverage could be used off of the LRDs to create an NCA to book the client correctly (US CDS colleagues advised that they did not believe the LKYCUS was to be further actioned) b. LKYC-GB to be approved to kick start the NCA & LRD/NRD dates within dbCAR v. Following the LKYC-GB being approved, the file was immediately reviewed and was deemed that the UK adoption location had been fixed vi. Subsequent Extension request was approved Many thanks to all that shared their knowledge, I will be looking further into KCP clients with UK adoptions to ensure that such scenarios do not become a recurrent theme. As always, please give me a shout if you have any questions. Kind regards, {logo} EFTA01400114 James Gladwin AFC Business Advisory Anti-Financial Crime DBOI Global Services (UK) Limited 5 Brindley Place, Birmingham, B1 2JB, United Kingdom Email: P Please consider the environment before printing this email From: James Gladwin Sent: 11 May 2018 18:44 To: Martin Zeman ; Jesse-J Cruz Cc: Kareen Johnson < ; Daniel-A Klyashtorny <daniel- ; Nina Tona ; Xavier Avila ; Davide-A Sferrazza -; AMLUK Reviews • ; Devshiji Odedra Ian Salters ; Simon Nall ; Ricky-x Patel Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] ; Zack Bunimovich Classification: For internal use only Hello all, I have had the pleasure with speaking directly with Martin and colleagues to assist UK AFC with this KCP Extension. UK AFC are kindly in receipt of the KCP GM policy dated June 2017 (duly noted that this is currently under review), this document has proved useful in giving context to the UK GM product nexus with solely a US booking. EFTA01400115 Due to the local UK time, I will be discussing KCP Extensions with my management on Monday as to best understand and process such requests in the future. I truly appreciate the time and knowledge that has been shared and look forward to our conversations next week as to support each other. Many thanks all, {logo} James Gladwin AFC Business Advisory Anti-Financial Crime DBOI Global Services (UK) Limited 5 Brindley Place, Birmingham, B1 2JB, United Kingdom Email: P Please consider the environment before printing this email From: James Gladwin Sent: 10 May 2018 09:47 To: Martin Zeman ; Jesse-J Cruz Cc: Kareen Johnson ; Daniel-A Klyashtorny <daniel- ; Nina Tona ; Xavier Avila ; Davide-A Sferrazza ; AMLUK Reviews • ; Devshiji Odedra Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] ; Zack Bunimovich EFTA01400116 Classification: For internal use only Hello all, Do we have BRG approval for this? This is appears to be a cross-jurisdictional adoption from DBSI to II AG, furthermore, the LRD for the US is 2016 and does not appear to be in the Remediation pipeline? For Extensions to be approved, AFC UK require: i. BRG approval to consider cross-jurisdictional approvals which result in newly booked High Risk clients ii. The file to be within NRD date and if not, must be within the Remediation pipeline — of which it appears it is neither @CDS colleagues, Please consider the above points, I am happy to further explain on the phone to assist our business colleagues & clients expectations. @Martin I will keep you updated on the progress made. Many thanks all, {logo} James Gladwin AFC Business Advisory EFTA01400117 Anti-Financial Crime DBOI Global Services (UK) Limited 5 Brindley Place, Birmingham, B1 2JB, United Kingdom Email: P Please consider the environment before printing this email From: Martin Zeman Sent: 08 May 2018 20:27 To: Zack Bunimovich ; AMLUK Reviews >; Jesse-J Cruz ; James Gladwin Cc: Kareen Johnson ; Daniel-A Klyashtorny <daniel- ; Nina Tona ; Xavier Avila ; Davide-A Sferrazza Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] Classification: For internal use only James — responding to your questions below. The extension is permanent. Southern Financial LLC trade global macro and are looking to buy CDX IG payer spreads as a hedge for their overall equities and fixed income portfolio they trade with U. The initial size is around $100M. Please call me if you need any more details. This is a priority for our desk. Thank you. From: Zack Bunimovich Sent: Tuesday, May 08, 2018 12:24 PM EFTA01400118 To: AMLUK Reviews James Gladwin Cc: Kareen Johnson < ; Martin Zeman >; Jesse-) Cruz <jesse- ; Daniel-A Kl ashtorny <daniel- ; Nina Tona Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] Classification: For internal use only +Nina From: Zack Bunimovich Sent: Tuesday, May 08, 2018 10:21 AM To: AMLUK Reviews >; Jesse-J Cruz <jesse- >; James Gladwin Cc: Kareen Johnson < ; Daniel-A K1 ashtorny <daniel- ; Martin Zeman Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] Classification: For internal use only Hi James, For ii, this is a permanent extension. Martin — can you advise on the questions from James in i. below? Thanks, Zack EFTA01400119 From: James Gladwin On Behalf Of AMLUK Reviews Sent: Tuesday, May 08, 2018 10:18 AM To: Jesse-J Cruz ; James Gladwin a> Cc: Kareen Johnson < ; Daniel-A Klyashtorny <daniel- ; Zack Bunimovich ; AMLUK Reviews Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] Classification: For internal use only Hi both, I am happy to help. Just a couple of immediate questions to help expedite this: i. a. ii. a. What is the business purpose for the extension? Elaborate on key details including; booked trades, expected volumes Is the extension request permanent or temporary? Please provide activation/closure dates if temporary FYI, Helen has been removed from the chain as she has left the bank. AMLUK.COMPLIANCE has been removed, AMLUK.REVIEWS primarily work extensions/reactivations now alongside our PRs/EDRs and not the aforementioned team. Many thanks! {logo} EFTA01400120 James Gladwin AFC Business Advisory Anti-Financial Crime DBOI Global Services (UK) Limited 5 Brindley Place, Birmingham, B1 2JB, United Kingdom Email: P Please consider the environment before printing this email From: Jesse-J Cruz Sent: 08 May 2018 15:06 To: AMLUK Reviews James Gladwin ; Helen Ncube Cc: Kareen Johnson < ; Daniel-A Klyashtorny <daniel- ; Zack Bunimovich RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial Subject: LLC [I] Classification: For internal use only James/Helen, Can you assist with this request? Please make top priority. Thanks, Jesse From: Zack Bunimovich EFTA01400121 Sent: Monday, May 07, 2018 3:51 PM To: Jesse-3 Cruz Cc: Kareen Johnson < ; AMLUK Reviews liance ; Daniel-A Klyashtorny <daniel- Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] Classification: For internal use only Classification: For internal use only Hi AML teams, Can you please revert on the below? Thanks, Zack From: Jesse-3 Cruz Sent: Thursday, May 03 2018 3:05 PM To: AMLUK Reviews ; amluk compliance Cc: Zack Bunimovich ; Kareen Johnson Subject: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] Classification: For internal use only Hi All, We are performing a principal product extension for Southern Financial, LLC for GED, Convertible Bonds, and Global Credit Derivatives in DBAG. DBcar triggered a high risk rating. Attached is an EDD package comprised of the EFTA01400122 following: Searches Formation documents Tax document Correspondence with client emails Financial statements Please let me know if you need any additional information. Kind regards, fcid:[email protected] Jesse Jay Cruz Analyst Deutsche Bank Securities Inc. Client Data Services I DBUSA Core Corp. 5201 Gate Parkway, 32256 Jacksonville, USA Tel: Email: EFTA01400123