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sd-10-EFTA01356279Dept. of JusticeOther

EFTA Document EFTA01356279

Patrick Harris Managing Director I Head, Business Risk Management Deutsche Bank Trust Company Americas WM Americas 345 Park Avenue. 10154-0004 New York. NY. USA BassiftoNT geronit From: Andrew Gallivan Sent: Friday, September 08, 2017 12:06 PM To: Patrick Harris Subject: RE: What are you presenting to the Risk committee Monday on high risk KYC's [II Classification: For Internal use only Also thinking about this for the medium risk KYC related to the previously exempted trusts let's en

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Patrick Harris Managing Director I Head, Business Risk Management Deutsche Bank Trust Company Americas WM Americas 345 Park Avenue. 10154-0004 New York. NY. USA BassiftoNT geronit From: Andrew Gallivan Sent: Friday, September 08, 2017 12:06 PM To: Patrick Harris Subject: RE: What are you presenting to the Risk committee Monday on high risk KYC's [II Classification: For Internal use only Also thinking about this for the medium risk KYC related to the previously exempted trusts let's en

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Patrick Harris Managing Director I Head, Business Risk Management Deutsche Bank Trust Company Americas WM Americas 345 Park Avenue. 10154-0004 New York. NY. USA BassiftoNT geronit From: Andrew Gallivan Sent: Friday, September 08, 2017 12:06 PM To: Patrick Harris Subject: RE: What are you presenting to the Risk committee Monday on high risk KYC's [II Classification: For Internal use only Also thinking about this for the medium risk KYC related to the previously exempted trusts let's engage the trust team to help gather all the necessary information. They will have direct client contact and should be able to handle that outreach. We may need to educate them on the intricacies of the new policy but they should be able to lift some of this burden. Ultimately the banker's name will need to be tagged to this from a completion monitoring standpoint but someone else can help in plowing through these....Thoughts7 From: Patrick Harris Sent: Friday, September 08, 2017 11:47 AM To: Andrew Gallivan Subject: RE: What are you presenting to the Risk committee Monday on high risk KYCs [I] You're right: "offered" should be deleted. Sent with Black Berry Work (www.blackberrv.com) From: Andress- Gallivan Date: Friday. Scp 08, 2017, I I :44 AM To: Patrick Harris Subject: RE: What arc you presenting to the Risk committee Monday on high risk KYC's Ill Classification: For Infernal use only 3'd bullet on page 9 wording seems off. I think we want to say has given written guidance but wanted to confirm with you From: Patrick Harris Sent: Friday, September 08, 2017 11:39 AM To: Andrew Gallivan Subject: RE: What are you presenting to the Risk committee Monday on high risk KYCs [I] CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042067 CONFIDENTIAL SDNY_GM_00188251 EFTA01356279

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