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sd-10-EFTA01401992Dept. of JusticeOther

EFTA Document EFTA01401992

Subject: RE: KYC Breach SOUTHFINANMD Southern Financial, LLC_FFT Location [I] From: Xavier Avila Date: Mon, 16 Apr 2018 07:44:03 -0400 To: Akash Malhotra Cc: Shawn Staker NCAOTC Derivatives Pankaj-A Chopra Alka Gopala Nina Tona Ian Salters Mathew Negus Martin Zeman Negus, what do we do with the below? If easy extension to OTC Rates FFT we can provide docs, if not we move this to London where client is onboarded? Thanks Xavier Avila Managing Director Deutsche Bank Securities Inc

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sd-10-EFTA01401992
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Subject: RE: KYC Breach SOUTHFINANMD Southern Financial, LLC_FFT Location [I] From: Xavier Avila Date: Mon, 16 Apr 2018 07:44:03 -0400 To: Akash Malhotra Cc: Shawn Staker NCAOTC Derivatives Pankaj-A Chopra Alka Gopala Nina Tona Ian Salters Mathew Negus Martin Zeman Negus, what do we do with the below? If easy extension to OTC Rates FFT we can provide docs, if not we move this to London where client is onboarded? Thanks Xavier Avila Managing Director Deutsche Bank Securities Inc

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Subject: RE: KYC Breach SOUTHFINANMD Southern Financial, LLC_FFT Location [I] From: Xavier Avila Date: Mon, 16 Apr 2018 07:44:03 -0400 To: Akash Malhotra Cc: Shawn Staker NCAOTC Derivatives Pankaj-A Chopra Alka Gopala Nina Tona Ian Salters Mathew Negus Martin Zeman Negus, what do we do with the below? If easy extension to OTC Rates FFT we can provide docs, if not we move this to London where client is onboarded? Thanks Xavier Avila Managing Director Deutsche Bank Securities Inc + 1 917 8541256 From: Akash Malhotra ‹ > Date: Monday, Apr 16, 2018, 07:34 To: Xavier Avila Cc: Shawn Staker , NCAOTC Derivatives , Pankaj-A Chopra as, Alka Gopala Subject: KYC Breach_SOUTHFINANMD_Southern Financial, LLC_FFT Location [I] Classification: For internal use only Hi Alex, For adoption location Frankfurt, the following trade has been booked in Summit application for OTC Derivative Product, details as follows: Trade ID: G175714L Summit Code: SOUTHFINANMD Date of Trade: 13/04/2018 Client Name: Southern Financial, LLC EFTA01401992 We have got your name as a sales person from Summit application. We have observed that the client is not adopted for Frankfurt location, which results in a KYC violation. In order to comply with DB's internal policies and procedures, all KYC requirements now have to be fulfilled, if the trade should stand against Deutsche Bank Kindly review your trade and where possible, please consider to rebook the trade to an adoption location, where the client is already adopted for OTC Derivative product or confirm if it is a valid trade for the particular location. Upon your confirmation, we will review the client and would request the missing documents to be obtained from the client/business as per Frankfurt location guidelines. Summit screenshot: Trade Details Regards Akash Malhotra Associate I Client on Boarding DBOI Global Services Private Limited Global Business Services A-1 & A-2, Evolve - Mahindra Technology Park, Inside Mahindra World City SEZ, 302029 Jaipur, India Tel. +44(207)3383-3462 Email EFTA01401993 Escalations Contact:- EFTA01401994

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Subject: RE: KYC Breach SOUTHFINANMD Southern Financial, LLC_FFT Location [I] From: Mathew Negus Date: Tue, 17 Apr 2018 09:10:47 -0400 To: Nina Tona Xavier Avila Cc: Ian Salters Martin Zeman Classification: For internal use only Extension to FFT goes to US Case Management. What's the mat date on the xccy swap? Mathew Negus Director I ICG Business Management I I I From: Nina Tona Sent: Tuesday, April 17 2018 8:32 AM To: Mathew Negus Jimmy-H Xu Xavier Avila ; Akash Malhotra Cc:

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