EFTA Document EFTA01368710

Deutsche Bank Compliance HUB SPOKE INTRODUCTION The Hub-Spoke rules are set up to identify multiple ordering parties sending to a single beneficiary and vice versa (a single ordering party sending to multiple beneficiaries). If the specific parameters for transaction type, dollar amount and number of transactions are met, the rule will flag the transactions. There are four versions of the rule, which are designed to wn monthly with a look-back period of 30 days. ANALYTICAL PROCESS Rule