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sd-10-EFTA01375680Dept. of JusticeOther

EFTA Document EFTA01375680

From: Vijay-A Sawant Sent: 8/24/2018 5:08:31 AM To: Stewart 0ldfiel I; Richard larossi CC: Mayur Rathod • Bradley Subject: RE: 2018 Periodic Review of High Risked Accounts GCISS, Butterfly Trust (GCIStta and Neptune, LLC (GCISMIll under the SOUTHERN FINANCIAL RELATIONSHIP Attachments: Southern Financial_No Material Changes Confirmation.pdf Importance: High Hello Richard, We have received material change confirmation from Brad on below accounts as per attached email. So following

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sd-10-EFTA01375680
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From: Vijay-A Sawant Sent: 8/24/2018 5:08:31 AM To: Stewart 0ldfiel I; Richard larossi CC: Mayur Rathod • Bradley Subject: RE: 2018 Periodic Review of High Risked Accounts GCISS, Butterfly Trust (GCIStta and Neptune, LLC (GCISMIll under the SOUTHERN FINANCIAL RELATIONSHIP Attachments: Southern Financial_No Material Changes Confirmation.pdf Importance: High Hello Richard, We have received material change confirmation from Brad on below accounts as per attached email. So following

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From: Vijay-A Sawant Sent: 8/24/2018 5:08:31 AM To: Stewart 0ldfiel I; Richard larossi CC: Mayur Rathod • Bradley Subject: RE: 2018 Periodic Review of High Risked Accounts GCISS, Butterfly Trust (GCIStta and Neptune, LLC (GCISMIll under the SOUTHERN FINANCIAL RELATIONSHIP Attachments: Southern Financial_No Material Changes Confirmation.pdf Importance: High Hello Richard, We have received material change confirmation from Brad on below accounts as per attached email. So following are list of items pending on these accounts - Butterfly trust — Kindly confirm if this is a Personal Trust and NOT Corporate Trust? After reviewing the trust agreement, we noticed that the UBO's seem not related to the grantor. The reason for this request is to evaluate whether we require CDD form for this account or not. NOTE: we require CDD form ONLY in case of Corporate Trusts. Neptune LLC — Please note that Richard Kahn has been added as manager as per Operating Agreement even though he was NOT added as an RP in the previously approved KYC Case#01790739. We will proceed to the next stages upon receipt of your confirmation of the above queries, thanks. Kind Regards, Vijay Sawant KYC Case Representative Deutsche CIB Centre Private Limited - Deutsche Bank Group Wealth Management B1, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway Goregaon East, Mumbai - 400O63, India Tea Mobt From: Vijay-A Sawant Sent: Tuesday, July 31, 2018 6:31 PM To: Bradley Gillin iiimumml>; Stewart Oldfield Cc: Mayur Rathod Subject: 2018 Periodic Review of High Risked Accounts-(GCIS , Butterfly Trust (GCISS and Neptune, LLC (GCIS# under the SOUTHERN FINANCIAL RELATIONSHIP Importance: High Hello Brad/Stewart, This review relates to above high risked three accounts due for remediation 08/31/2018. Upon review of the dots available in the repositories, we have completed the attached checklist, main RP's also listed below for reference — CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0071238 CONFIDENTIAL SDNY_GM_00217422 EFTA01375680

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