EFTA Document EFTA01362908

Do we have BRG approval for this? This is appears to be a cross-jurisdictional adoption from DBSI to DB AG, furthermore, the LRD for the US is 2016 and does not appear to be in the Remediation pipeline? For Extensions to be approved, AFC UK require: i. BRG approval to consider cross-jurisdictional approvals which result in newly booked High Risk clients ii. The file to be within NRD date and if not, must be within the Remediation pipeline — of which it appears it is neither @CDS colleagues, Please consider the above points, I am happy to further explain on the phone to assist our business colleagues & clients expectations. @Martin I will keep you updated on the progress made. Many thanks all, James Gladwin AFC Business Advisory Anti-Financial Crime DB0I Global Services (UK) Limited S Brindle Place Birmin ham B1 218, United Kingdom Email: BA Pleate consider the environment before printing this email From: Martin Zeman Sent: 08 May 2018 20:27 To: Zack Bunimovich Cruz Cc: Kareen Johnso Nina Tona • AMLUK Reviews Daniel-A Klyashtorny Davide-A Sferrazza Subject: RE: Escalation: DNB-1135648 / LKYCGB-160049 / Southern Financial LLC Ill ; Jesse-J Classification: For Internal Use only James — responding to your questions below. The extension is permanent. Southern Financial LLC trade global macro and are looking to buy COX IG payer spreads as a hedge for their overall equities and fixed income portfolio they trade with DB. The initial size is around $100M. Please call me if you need any more details. This is a priority for our desk. Thank you. From: Zack Bunimovich Sent: Tuesday, May 08, 2018 12:24 PM To: AMLUK Reviews Jesse-1 Cruz James Gladwin Cc: Kareen Johnson Daniel-A Klyashtorny CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0052593 CONFIDENTIAL SDNY_GM_00198777 EFTA01362908