EFTA Document EFTA01356788

From: Oliver Esslin Sent: 5/29/2019 3:40:54 PM To: Ian Salters Hart I; Funda Bozkurt ; Janice Franklin Subject: Managed Exit account handling Attachments: Mane ed Exits.xlsx Location: Start: 5/30/2019 11:00:00 AM End: 5/30/2019 11:30:00 AM Show Time As: Tentative Recurrence: (none) ; Bill King ; Maria Pedulla • Kimberly Term Definition PA Checks/Review Review of client account activity to establish open obligations which prevent onboard A process state for client entities identified for offboarding but have open obligations which prevent process completion The process of sending a client notification to terminate the contractual relationship at the end of a defined notice period The process of closing DB transactional system accounts representing the impacted client entity A count of client entities which have completed all offboarding process stages, and are inactivated through to KYC Records - classified as 'Full' Oftboard when evidenced, complete removal of client entity from all businesses & jurisdictions inclusive of all tech platforms. Applied to all DB adoption entities globally. Managed Exit Notification In Closure Ofiboarded Below is how the CIB process works: • The client is marked to be Off-Boarded but cannot be as there is an outstanding obligation (i.e. loan or position) with the client • Client has been deemed to be KYC relevant by Business • Managed Exit team searches in paid/public sources for the 4 below attributes • Proof of Existence • Legal Representatives • Ownership/IBO • Identity (ID)/Nationality & Source of Wealth (SOW) (Net Worth & source from where it is acquired) • If not found, 2 notification letters are dispatched to the client seeking information • Business is not involved in the sourcing of data • Case is enriched • KYC is collected on a best effort basis and if all 4 attributes cannot be sourced it is notated in the file • Account will be quarantined until the obligation/position expires • ACO signs off on the Managed Exit CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042864 CONFIDENTIAL SDNY_GM_00189048 EFTA01356788