EFTA Document EFTA01407567

Subject: Re: ACTION REQUIRED: Issue related to ACUs [I] From: Amanda Kirby ‹ > Date: Tue, 13 Oct 2015 19:08:02 -0400 To: Armen Brash Paul Morris Jj Litchford Classification: For Internal Use Only Ill work with JJ on these From: Armen Brash Sent: Tuesday, October 13, 2015 06:36 PM To: Paul Morris; Amanda Kirby Subject: ACTION REQUIRED: Issue related to ACUs [I] Classification: For internal use only Paul and Amanda, As you may know, per the AML Procedures manual, certain clients are excluded from ACUs. An issue has been identified in dbforce where High Risk clients are given an ACU Auto Exemption for Retail Banking, however, per Policy, this exception does NOT apply to High Risk clients. Unfortunately, the code in dbforce exempting high risk clients with only deposit accounts under $250K from the ACU when it should not be—the code will be fixed ASAP, but in the meanwhile, while the ACUs listed below don't appear as overdue, they must be completed by year end. Customer Name Customer # Relationship Primary Officer ACU Completed Date EFTA01407567 Butterfly Trust SOUTHERN FINANCIAL RELATIONSHIP Paul Morris The 2007 Jeffrey E. Epstein Insurance Trust #3 SOUTHERN FINANCIAL RELATIONSHIP Paul Morris New York Strategy Group, LLC SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Plan D, LLC SOUTHERN FINANCIAL RELATIONSHIP Paul Morris HBRK Associates, Inc SOUTHERN FINANCIAL RELATIONSHIP EFTA01407568 Paul Morris Hyperion Air, LLC SOUTHERN FINANCIAL RELATIONSHIP Paul Morris JEGE, Inc SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Neptune, LLC SOUTHERN FINANCIAL RELATIONSHIP Paul Morris SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Zorro Development Corp. EFTA01407569 SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Gratitude America SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Please let me know if you have any questions and please let me know when this has been completed. Best, Armen Armen Brash Director Deutsche Asset & Wealth Management 345 Park Avenue, 10154-0004 New York, NY, USA EFTA01407570 Tel. Fax Mobile Email EFTA01407571