EFTA Document EFTA01408513

Subject: FW: Combined KYC list and priorities [I] From: Ian Salters ‹ > Date: Sun, 24 Feb 2019 14:33:19 -0500 To: Davide-A Sferrazza Nina Tona FYI Sent with BlackBerry Work (www.blackberry.com) From: Oliver Esslinge Date: Sunday, Feb 24, 2019, 14:30 To: Brian H Heidelbach Bill King Cc: Emily Craig Anas Malin] Subject: Re: Com ine ist an' priorities [I] Thank you very much Brian and Emily. Ian/Bill: Ian Salters We are pulling KYC stats for OTC derivatives clients. Unfortunately the names do not match for the client names enclosed. Can you please review DB Force and provide Brian with GCIS numbers for those 100 IWP and Cap Mkts clients? Thank you. Oliver On Feb 24, 2019, at 14:03, Brian H Heidelbach wrote: Classification: For internal use only See the attached file. I added the columns in yellow. EFTA01408513 The following names do not exist verbatim in dbForce: 140-154 W 72 Realty LLC 198-202 Elizabeth Street LLC 239-243-247 W 21 Realty LLC 23rd Street, LLC 245 E 19 REALTY LLC 250 E 63 REALTY LLC 509 Madison Avenue Associates LP Allen, Paul Gardner Amazonia SP Amir Weissfisch AMZAK Capital Management ANTONY S & JANET C WILLIAMS Arclight Energy Partners Fund V LP Banco Invex, SA, Institucion de Banca Multiple, INVEX Grupo Financiero as Trustee to Fideicomiso No 911 Belford Investments Ben Nevis Partnership SP Bhat, Nityanand BioDuro LLC Burger, Peter BURO INMOBILIARIO AVANTI SA DE CV Camphill Village Copake Foundation, Inc EFTA01408514 CHARLES M VON ARENTSCHILDT TR UAD 04/19/12 CHARLES & MEREDITH TTEES Charles Stein Chicago NBC Tower Investments, Inc CORDISH ENTERPRISES II LLLP CROWN WATERIDGE ASSOCIATES LP CUSTODY ERRORS & CLAIMS ACCOUNT MISC Daniel and Suzanne Cohen DAVID TODD STEVENS DAVID W ZALAZNICK & BARBARA M ZALAZNICK DB Zurich Diro PTE LTD Elysee of Brickell LLC EQUINIMITY LLC ETERNITY LIMITED Euro-Partners Fund FIDEICOMISO BANAMEX 16730-2 Fouad Chartouni FRANCISCO AGUSTIN COPPEL LUKEN Gabena PTE LTD GEOFFREY H PALMER TRUST GEORGE B KAISER GOLDENTREE ASSET MANAGEMENT LP Gracie Investing, LLC GUY WYSER PRATTE H/D INVESTORS FUND LP EFTA01408515 Harmonia International Ltd. Hartz Capital Investments, LLC HENRY RITCHOTTE Heritage Investing Inc Humility Ltd ICARO INVESTMENTS LIMITED Inmobiliaria Evian-Chamonix SA de CV IN-REL Properties Inc Inverban SA James E Ferrell Revocable Trust Two James P Kellner & Michele D Kellner JANA HOLDINGS LLC JESUS MANUEL MUNOZ and MARYEN MUNOZ JOHN R MILLER ENTERPRISES LLC JOHN W CHILDS JONATHAN BLOOSTEIN JORGE LUIS ORBAY & MARIA MARGARITA TREMOLS Josiko Properties LLC Juergen and Meifang Buchsteiner JWM Family Enterprises, Inc Karlin Las Palmas Subsidiary, LLC KIFENOR SA KLAUS NEHRING Lenton Properties Inc Lepow, Howard Linton Grove Holdings LLC EFTA01408516 MC2 Holdings LLC Meister, Keith A Milber Holdings LLC MONTECO INTERNATIONAL CORP Mulberry Vine Limited OP, LLC PARKWOOD LLC Parmer RTP LLC PETER FINE PINEWOLD MANAGEMENT COMPANY LP PRIVATE WEALTH MANAGEMENT NEW YORK PRIVATE WEALTH MANAGEMENT NY AC PB US ONSHORE PRODUCTIVE HOLDINGS S A Railroad Properties LLC RAJ BHATTACHARYYA Robert L Allbritton Ronald W Burkle SCA Ventures LLC Sincock II, Craig R SOMERSTON INVESTMENTS LTD Southern Fox Investments Ltd Southern Trust Company Inc STEVEN A TANANBAUM STEVEN J KASSIN & ISAAC S FRANCO JOINTLY & SEVER Stitzer, Howard T EFTA01408517 T CO Metals LLC TENDENCIA ASSET MANAGEMENT LTD THE FLORESCUE FAMILY CORP The Gary E Primm Family Trust dated April 10, 1984 THE JAMES P KELLNER 2008 IRREVOCABLE TRUST The MST Trust THE PETER MULLIN FAMILY TRUST UDT DTD 12-18-2000 Third Street Mall Properties, LLC Thomas Point Ventures LP Tilman J. Fertitta Timothy Rattray TOW, LEONARD RELATIONSHIP TRUMBULL EQUITIES LLC Vanguardia Inversiones SAS Visper Pte Ltd Vitton, Michael BrinHi l ch From: Emily Craig Sent: Sunday, Februar 24 2019 1:45 PM To: Oliver Esslinger Brian H Heidelbach Cc: Anas Halim Subject: RE: Combined KYC list and priorities [I] EFTA01408518 Classification: For internal use only They look to be exact to Client Name in dbForce. Kind Regards, Emily <image001.png> Emily Craig Director Deutsche Bank Wealth Management Deutsche Bank Securities, Inc 1 South Street, Baltimore, MD 21202-3298 From: Oliver Esslinger Sent: Sunday, February 24, 2019 1:40 PM To: Brian H Heidelbach Cc: Emily Craig Anas Halim EFTA01408519 Subject: Re: Combined KYC list and priorities [I] Those should be the names in dB force. Please don't kill yourselves with this but we would need to understand whether we have full completed and approved KYCs on file for those or what status is. If you cannot find Name match right away I will reach out to product teams and ask for review. Best regards Oliver On Feb 24, 2019, at 13:35, Brian H Heidelbach wrote: Classification: For internal use only Are the names verbatim, as they appear in dbForce? ch From: Emily Craig Sent: Sunday, February To: Brian H Heidelbach Cc: Oliver Esslinger Subject: FW: Combinelli stat priorities ] ; Anas Halim EFTA01408520 Classification: For internal use only Brian/Anas, Can we get last KYC date, risk, Primary Officer/ACO, for attached list? Tricky part will be we don't have GCIS numbers in this view. Kind Regards, Emily <image001.png> Emily Craig Director Deutsche Bank Wealth Management Deutsche Bank Securities, Inc 1 South Street, Baltimore, MD 21202-3298 WM Mercury on myDB EFTA01408521 From: Oliver Esslinger Sent: Saturday, 7 AM To: Emily Craig Subject: Fwd: Combined KYC list and priorities [I] Hi Emily Not sure what if any engagement occurred from your end or from somebody in your team on this in the past. I am coordinating agenda with local and UK WM and CIB stakeholders going forward. One question I have for you is whether your team can assist in checking KYC status for those 200+ clients as per attachment. In case CIB is asking for docs to rely upon etc tbd i would like to understand if all of those have already been remediated or if not can be prioritized/offboarded etc. Do you by chance have somebody that could look into this next week (maybe Passcon assuming most are MR and LR) and amend table with KYC status accordingly? Let me know please. Looking forward to seeing you again in Jax for comm day. Cheers Oliver EFTA01408522 Begin forwarded message: From: Oliver Esslinger Date: February 22, 2019 at 19:57:24 EST To: Ian Salters Bill King Cc: Thomas Klemm >, Victoria Subject: FW: Combined KYC list and priorities [I] Classification: For internal use only Hi Ian/Bill: Thanks for your input provisions, I took the liberty to review and clean up the files, we have now also added ISG RM names and potential KYC outreach contacts going forward. Our key focus for now should be have a complete inventory of clients in scope including prioritization to share with CIB for identification of action items and time lines. In this context I ask you to amend the template as following: - Column M: Based on CIB business differentiation by OTC product (FX vs IR) please flag what kind of exposure the clients have, I hope and assume that it will not matter from a contractual documentation perspective, nevertheless we should have this breakdown for future reviews - Column 0: For the clients that are not a priority and without current CIB KYC in place is offboarding a feasible alternative (62 or almost 50% for ISG and 30 or almost 40% of IWP clients)? If offboarding is not an option, please provide business rationale/commercial viability. - other outstanding tab: I am not clear on the purpose probably lacking historic discussions, upon review I highlighted counterparty names which were already captured in first tab, hence not sure what is outstanding here. Only 7 names are not covered yet, can you please advise, clarify? PS: I will see Vicky on Monday to review next steps also to be discussed in upcoming call hence keeping this in small circle for now . EFTA01408523 Best Oliver <OTC Derivatives Project WM Client list Feb 22.xlsx.secure> EFTA01408524