EFTA Document EFTA01403280

Subject: Discussion : Gratitude America Ltd From: Vinita Advani <[email protected]> Date: Wed, 12 Sep 2018 09:27:43 -0400 To: Daphne Cales <[email protected]>, Bradley Gillin <[email protected]>, Vijay-A Sawant <[email protected]> Cc: Holger Pauco-Dirscherl <[email protected]>, Holger Pauco-Dirscherl <[email protected]>, Derek St-Hilaire <[email protected]> Vijay, Can you please set some time for all of us to discuss tomorrow? I received some clarity from the ABR team. Thank you. Kind regards, Daphne Cales Daphne Cales Director I Banking Services & Branch Manager Deutsche Bank Trust Company Americas WM Americas 345 Park Avenue, 10154-0004 New York, NY, USA Tel. +1 212 250-6535 Fax +1 212 454-9719 Mobile +1 917 257-2497 Email [email protected] From: Vijay-A Sawant Sent: Tuesday, September 11, 2018 9:29 AM To: Daphne Cales <[email protected]> Cc: Vinita Advani <[email protected]> Subject: FW: Rejection Points KYC # - 01977700 [I] Importance: High Hi Daphne, As discussed on call today, following are case rejections we have received EFTA01403280 from KG. Point 1 identifies the donor as UBO and this info can be verified from Pg 53 of the US Addendum, relevant paragraph provided below for reference. Also attached in this email are the Form 990's for year's 2014, 2015 & 2016. You can see that the $10mn donation was received in 2015. Previously approved KYC Case01790739 was approved in Aug 2017 where this donor was not identified. Why is this an EDR now? Please advise how to proceed with this? Case #: 01977700 Relationship: SOUTHERN FINANCIAL RELATIONSHIP Customer Name: Gratitude America Ltd Customer Number: 00000499760 Reason for Rejection:The case was not reviewed in its entirety due to the below issues. Once this has been resolved, we will review the case. This will now be treated as an EDR. 1) As per the 2015 Form 990 (attached to the KYC by AFC), BV70 LLC donated $10MM to this foundation and thus making them a "significant Donor". We need to fully KYC this entity. Please provide the required documentation and information. 2) Please provide ExCo approval as this is now an EDR. 3) Please provide the FinCEN form. Thanks in advance for helping with this. 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 - 400063 , India Tel. +91(22)6181-1485 Mobile +91 9833729812 [email protected] EFTA01403281