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sd-10-EFTA01364969Dept. of Justice

EFTA Document EFTA01364969

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From: Ariane Dwyer Sent: 1/28/2016 8:08:02 AM To: Daniel Sabba Subject: FW: Gratitude KYC IIJ ; Vahe Stepanian Per Fran's email below we now have two options: 1. Sent does to be reviewed by AML Compliance. I'm not sure why it is a "high risk", but it could be because of JE? 2. Complete reputational risk document with Paul given that JE founded the foundation per the Articles of Incorporation and my call with Rich Let me know what you think. Best, Ari From: Fran M Wickman Sent:

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Dept. of Justice
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sd-10-EFTA01364969
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