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EFTA Document EFTA01362522EFTA Document EFTA01362524
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sd-10-EFTA01362523Dept. of JusticeOther

EFTA Document EFTA01362523

- Annual report r≥ See attachments "Southern Financial LLC Financials June 2017" and "Southern Trust Company Inc. Financials June 2017" for latest financial statements Thank you Nina Tona From: Zack Bunimovich Sent: Tuesday, March 13, 2018 11:16 AM To: Martin Zeman < Cc: Nina Tona ; Jitan Patel < A Sferrazza <davide- Subject: RE: SF [I] ICJ Classification: Confidential Hi Martin, >; Xavier Avila < ; Rita Shteynberg >; Mathew Negus >; Alastair Mackinlay < >; Anthony Lentini < ;

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sd-10-EFTA01362523
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- Annual report r≥ See attachments "Southern Financial LLC Financials June 2017" and "Southern Trust Company Inc. Financials June 2017" for latest financial statements Thank you Nina Tona From: Zack Bunimovich Sent: Tuesday, March 13, 2018 11:16 AM To: Martin Zeman < Cc: Nina Tona ; Jitan Patel < A Sferrazza <davide- Subject: RE: SF [I] ICJ Classification: Confidential Hi Martin, >; Xavier Avila < ; Rita Shteynberg >; Mathew Negus >; Alastair Mackinlay < >; Anthony Lentini < ;

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Text extracted via OCR from the original document. May contain errors from the scanning process.
- Annual report r≥ See attachments "Southern Financial LLC Financials June 2017" and "Southern Trust Company Inc. Financials June 2017" for latest financial statements Thank you Nina Tona From: Zack Bunimovich Sent: Tuesday, March 13, 2018 11:16 AM To: Martin Zeman < Cc: Nina Tona ; Jitan Patel < A Sferrazza <davide- Subject: RE: SF [I] ICJ Classification: Confidential Hi Martin, >; Xavier Avila < ; Rita Shteynberg >; Mathew Negus >; Alastair Mackinlay < >; Anthony Lentini < ; Davide- I just received the finalized KYC review yesterday. Even though the entity is opened for other products, it is outside of its KYC review date and is triggering a high risk rating. In order to approve the account, the team will need the following: - Ownership - Broken down to 10% (Org chart with %'s of ownership or confirmation from Senior Client Rep explaining the ownership breakdown) Legal Reps — Identify and Verify UBO's - Identify and Verify Source of Funds — Identification & Verification (Annual Report) Source of Wealth — Identify and Verify - Client Contact for Patriot Act disclosure email Formation Document (Cert of Incorp, etc) - Nature of Business Doc Thanks, Zack From: Martin Zeman Sent: Monday, March 12, 2018 10:19 AM To: Zack Bunimovich Cc: Nina Tona A Sferrazza Subject: RE: SF [I] [C] Zach Price Classification: Confidential Morning Zack, >; Xavier Avila >; Mathew Negus Alastair Mackinlay We haven't heard back from you on Friday. Can you let us know what the timeline looks like today please? Thanks, Martin Davide- CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0051965 CONFIDENTIAL SDNY GM_00198149 EFTA01362523

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Subject: RE: SF [I] [C] From: Nina Tona Date: Tue, 13 Mar 2018 11:41:22 -0400 To: Zack Bunimovich Martin Zeman Xavier Avila Cc: Rita Shteynberg Mathew Negus titan Patel Alastair Mackinlay Davide-A Sferrazza Anthony Lentini Classification: Confidential Zack, I believe some of the below was already provided back in Feb. Please review below and attached to make sure they are sufficient and we'll get back on the additonal. Ownership - Broken down to 10% (Org chart with %'s of owners

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From: Sent: To: CC: Nina Tona 3/13/2018 11:41:22 AM Zack Bunimovich • Martin Zeman Xavier Avila Rita Shteynberg Alastair Mackinla Anthony Lentini Mathew Negus ; Man Patel ; Davide-A Sferrazza Subject: RE: SF (I) (C) Attachments: Southern Financial Operating Agreement.pdf; Southern Trust Company Inc. Financials June 2017.pdf; Southern Financial LLC Financials June 2017.pdf Classification: Confidential Zack, i believe some of the below was already provided back in Feb. Please

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Subject: Southern Financial LLC - KYC and credit derivatives/convertible bonds onboarding [C] From: Martin Zeman < Date: Wed, 14 Mar 2018 17:08:50 -0400 To: Zack Bunimovich Rita Shteynber Jitan Patel Cc: Xavier Avila Liam Osullivan Mathew Negus Alastair Mackinlay Davide-A Sferrazza Anthony Lentini Classification: Confidential Zack, See attached for what Nina Tona sent in the last email in this chain and I am adding the Formation Document. This should complete everything you asked

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