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sd-10-EFTA01357149Dept. of JusticeOther

EFTA Document EFTA01357149

Jonathan Whittle >; James Gladwin Subject: Re: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LIC Ill Good day Nick - We have an issue here where in dbCAR this relationship did not reflect an old GB review date. We can see in the master profile that the relationship was created several years ago under DBAG, but now when extending for a new product, the review was missing completely. The file was escalated to AML for review and approved . This action triggered a GB review date

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sd-10-EFTA01357149
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Jonathan Whittle >; James Gladwin Subject: Re: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LIC Ill Good day Nick - We have an issue here where in dbCAR this relationship did not reflect an old GB review date. We can see in the master profile that the relationship was created several years ago under DBAG, but now when extending for a new product, the review was missing completely. The file was escalated to AML for review and approved . This action triggered a GB review date

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Jonathan Whittle >; James Gladwin Subject: Re: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LIC Ill Good day Nick - We have an issue here where in dbCAR this relationship did not reflect an old GB review date. We can see in the master profile that the relationship was created several years ago under DBAG, but now when extending for a new product, the review was missing completely. The file was escalated to AML for review and approved . This action triggered a GB review date for the very first time. Is it possible this was a merger issue? Please let me know if your team could take a look and if additional information is needed. Thank you! Kareen Johnson On May 18, 2018, at 12:11 PM, James Gladwin < Classification: For Miami use only Hi Simon, Absolutely, quite simply: wrote: i. Our Jacksonville CDS colleague, Kareen Johnson, will be reaching out to the dbCLIENT merger team to query the status/success of the KCP merge from dbCLIENT to dbCAR a. @Kareen, it would be great if I could be CCd in to your correspondence so that AFC can be advised accordingly ii. Nina Tona from business side will be providing myself with the list of KCP clients so that I can conduct a sanity sample check Both colleagues have been instrumental in assisting with this extension request. I will provide feedback on the above in due course. Kind regards, • imagchillgir James Gladwin AFC. Business Advisory Anti-Financial Crime DBOI Global Services (UK) Limited 5 Brindle Place, Birmin ham, El1 2JB, United Kingdom Please consider the environment before printing this email From: Simon Nall Sent: 16 May 2018 15:26 To: James Gladwin ; Martin Zeman IIIMMIa Cc: Kareen Johnson Daniel-A Klyashtorny a>: Nina Tona a; Xavier Avila Davide-A Sferrazza AMLUK Reviews Devshiji Odedra Ian Salters < >; Ricky-x Patel a>; Jesse-1 Cruz CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0043517 CONFIDENTIAL SDNY_GM_00189701 EFTA01357149

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Email From: James Gladwin Sent: 16 May 2018 15:19 To: Martin Zeman Cc: Kareen Johnson A; Daniel-A Klyashtorny < Nina Tona Ulli lia>; Xavier Avila < IMIIIIIMM; Davide-A Sferrazza <=a.; AMLUK Reviews <a; Devshiji Odedra Ian Salters Simon Nall Ricky-x Patel mi ngin; Jessed Cruz < ; ac Bunimovich Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC Ill Classification: For Internal use only Hello all, After liaising with Global CDS teams and specialist col

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