EFTA Document EFTA01430854

Subject: RE: USA Patriot Act Customer Identification Program Notification From: Stewart Oldfield ‹ > Date: Mon, 11 Jun 2018 14:12:54 -0400 To: Richard Kahn ‹ > Cc: Bradley Gillin It should work, but when we know people are traveling we notify the fraud team so nothing gets blocked. Let me see if we can do something more general for him Thanks From: Richard Kahn [mailto: Sent: Monday, June 11, 2018 2:11 PM To: Stewart Oldfield Subject: Re: USA Patriot Act Customer Identification Program Notification thank you france dates not yet certain was thinking of a more regular ongoing vs particular dates.. thanks Richard Kahn HBRK Associates Inc. 575 Lexington Avenue 4th Floor New York, NY 10022 tel fax cel EFTA01430854 On Jun 11, 2018, at 2:08 PM, Stewart Oldfield ‹ > wrote: I'm guessing it's generated from the global markets accounts we reactivated recently, but let me confirm. Please also send me JEE's dates for France. Thanks From: Richard Kahn [mailto: Sent: Monday, June 11, 2018 1:40 PM To: Stewart Oldfield Subject: Fwd: USA Patriot Act Customer Identification Program Notification do you know what this relates to? Richard Kahn HBRK Associates Inc. 575 Lexington Avenue 4th Floor New York, NY 10022 tel fax cell EFTA01430855 Begin forwarded message: From: Nathan Head Subject: USA Patriot Act Customer Identification Program Notification Date: June 11, 2018 at 1:35:47 PM EDT To: 'Richard Kahn' ‹ > Cc: Joshua Chin-Sang <image001.png> Dear Client — Southern Financial, LLC Subject: USA PATRIOT Act Section 326 Customer Identification Program & Regulation GG <image002.png> EFTA01430856 IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT USA PATRIOT Act Section 326 Customer Identification Program To help the government fight the funding of terrorism and money laundering activities, pursuant to Federal regulations that became effective on October 1, 2003, Section 326 of the USA PATRIOT Act requires all financial institutions to obtain, verify, and record information that identifies each person or legal entity that opens an account. What this means for you: When you open an account, we will ask for your name, address, and other information that will allow us to identify you. We may also ask you to provide other identifying documents, such as articles of incorporation, an offering memorandum, or other identifying documents. In addition, please find attached Deutsche Bank's BCM Program's Client Disclosure letter for your reference. The Following Applies to Non-US Correspondent Banks Only Pursuant to U.S. regulations issued under section 311 of the USA PATRIOT Act, see 31 CFR 1010.658, Deutsche Bank is required to notify you that we are prohibited from establishing, maintaining, administering, or managing a correspondent account for, or on behalf of the following which are defined collectively as "311 designated banks": Banco Delta Asia or any of its subsidiaries (including, but not limited to, Delta Asia Credit Limited, and Delta Asia Insurance Limited). Commercial Bank of Syria or any of its subsidiaries (including Syrian EFTA01430857 Lebanese Commercial Bank) FBME Bank Ltd (f.k.a. Federal Bank of the Middle East Ltd.) or any of its subsidiaries Malawi Exchange Co. or any of its subsidiaries Kassem Rmeiti & Co. For Exchange or any of its subsidiaries The regulations also require us to notify you that your correspondent account with our financial institution may not be used to provide the 311 designated banks with access to our financial institution. If we become aware any of the 311 designated banks are indirectly using the correspondent account you hold at our financial institution, we will be required to take appropriate steps to prevent such access, including terminating your account. Regulation GG Pursuant to the Unlawful Internet Gambling Enforcement Act of 2006 ("UIGEA") and implementing regulations issued by Federal regulatory authorities ("Regulation GG"), the U.S. subsidiaries and affiliates of Deutsche Bank ("DBUS") are, where applicable, required to develop policies and procedures that are reasonably designed to prevent payments in connection with unlawful Internet gambling (such payments are deemed to be "restricted transactions"). As part of Deutsche Bank's compliance with Regulation GG, we will be enhancing our customer due diligence to identify risks of unlawful Internet gambling, submitting required notices and rejecting ALL restricted transactions attempted to be processed through any account you maintain with a DBUS entity. A Restricted Transaction means any of the following transactions or transmittals involving any credit, funds, instrument, or proceeds that the UIGEA prohibits any person engaged in the business of betting or wagering (which does not include the activities of a financial transaction provider, or any interactive computer service or telecommunications service) from knowingly accepting, in connection with the participation of another person in unlawful Internet gambling: Credit, or the proceeds of credit, extended to or on behalf of such other person (including credit extended through the use of a credit card); EFTA01430858 An electronic fund transfer, or funds transmitted by or through a money transmitting business, or the proceeds of an electronic fund transfer or money transmitting service, from or on behalf of such other person; or Any check, draft, or similar instrument that is drawn by or on behalf of such other person and is drawn on or payable at or through any financial institution. Please assist us in this endeavor by refraining to submit to any DBUS entity any U.S. dollar transaction involving directly or indirectly Internet gambling activity. Sincerely, <image003.gif> Client Data Services Deutsche Bank USA Core Corporation 5201 Gate Parkway Jacksonville, FL 32256 USA Email: Lee Joyner - EFTA01430859 Jacob Goss - Jesse Cruz- Jacob Brandenburg Yonette Carrington - This communication may contain confidential and/or privileged information. If you are not the intended recipient (or have received this communication in error) please notify the sender immediately and destroy this communication. Any unauthorized copying, disclosure or distribution of the material in this communication is strictly forbidden. Please refer to https://db.com/disclosures for additional EU corporate and regulatory disclosures. Deutsche Bank does not render legal or tax advice, and the information contained in this communication should not be regarded as such. EFTA01430860 This communication may contain confidential and/or privileged information. If you are not the intended recipient (or have received this communication in error) please notify the sender immediately and destroy this communication. Any unauthorized copying, disclosure or distribution of the material in this communication is strictly forbidden. Please refer to https://db.com/disclosures for additional EU corporate and regulatory disclosures. Deutsche Bank does not render legal or tax advice, and the information contained in this communication should not be regarded as such. This communication may contain confidential and/or privileged information. If you are not the intended recipient (or have received this communication in error) please notify the sender immediately and destroy this communication. Any unauthorized copying, disclosure or distribution of the material in this communication is strictly forbidden. Please refer to https://db.com/disclosures for additional EU corporate and regulatory disclosures. Deutsche Bank does not render legal or tax advice, and the information contained in this communication should not be regarded as such. EFTA01430861