EFTA Document EFTA01357151

a. KCP clients had migrated from dbCLIENT to dbCAR, potentially the migration did not complete correctly (this will continue to be investigated SEPERATELY to this Extension request) b. At the very first adoption of the client/extension to UK GM products, this was not correctly booked within our internal systems iv. Fixes to the dbCAR profile were discussed between Global CDS teams, of which the latter was chosen due to time constraints and the impact upon our first line colleagues; a. LKYC-US to be reviewed and approved by US colleagues which would subsequently updated the LRD/NRD dates, subsequent leverage could be used off of the LRDs to create an NCA to book the client correctly (US CDS colleagues advised that they did not believe the LKYCUS was to be further actioned) b. LKYC-GB to be approved to kick start the NCA & LRD/NRD dates within dbCAR v. Following the LKYC-GB being approved, the file was immediately reviewed and was deemed that the UK adoption location had been fixed vi. Subsequent Extension request was approved Many thanks to all that shared their knowledge, I will be looking further into KCP clients with UK adoptions to ensure that such scenarios do not become a recurrent theme. As always, please give me a shout if you have any questions. Kind regards, <imagc00 James Gladwin AFC Business Advisory Anti-Financial Crime DBOI Global Services (UK) Limited S Brindley Place, Birmingham, B1 2JB, United Kingdom Email A Please consider the environment before printing this email From: James Gladwin Sent: 11 May 2018 18:44 To: Martin Zeman < ; Zack Bunimovich ; Jesse-J Cruz Cc: Kareen Johnson ; Daniel-A Klyashtorny >; Nina Tona S; Xavier Avila ; Davide-A Sferrazza ; AMLUK Reviews <[email protected]>; Devshiji Odedra < ; Ian Salters ifi ; Simon Nall < Ricky-x Patel <■_ Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC Classification: For internal use only Hello all, I have had the pleasure with speaking directly with Martin and colleagues to assist UK AFC with this KCP Extension. CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0043519 CONFIDENTIAL SDNY_GM_00189703 EFTA01357151