EFTA Document EFTA01407755

Subject: RE: ACTION REQUIRED: Issue related to ACUs [I] From: Paul Morris ‹ > Date: Tue, 27 Oct 2015 11:15:15 -0400 To: Jj Litchford Amanda Kirby Classification: For internal use only Thanks Paul Morris Managing Director Deutsche Bank Private Bank Office: Cell: From: Jj Litchford Sent: Tuesday, October 27, 2015 11:15 AM To: Paul Morris; Amanda Kirby Subject: RE: ACTION REQUIRED: Issue related to ACUs [I] Classification: For internal use only Yes, I did them right away and let Armen know. fcid:[email protected] JJ Litchford Associate Banker Deutsche Bank Trust Company Americas Deutsche Asset & Wealth Management 345 Park Avenue, 24th Floor EFTA01407755 New York, New York 10154 Tel. Mobile Email {cid:[email protected]} From: Paul Morris Sent: Tuesday, October 27, 2015 11:13 AM To: Amanda Kirby; Jj Litchford Subject: FW: ACTION REQUIRED: Issue related to ACUs [I] Classification: For internal use only Hi, did we finish these? Paul Morris Managing Director Deutsche Bank Private Bank Office: Cell: From: Armen Brash Sent: Tuesday, October 13, 2015 6:37 PM To: Paul Morris; Amanda Kirby Subject: ACTION REQUIRED: Issue related to ACUs [I] Classification: For internal use only EFTA01407756 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 Butterfly Trust SOUTHERN FINANCIAL RELATIONSHIP Paul Morris The 2007 Jeffrey E. Epstein Insurance Trust #3 SOUTHERN FINANCIAL RELATIONSHIP Paul Morris EFTA01407757 New York Strategy Group, LLC SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Plan D, LLC SOUTHERN FINANCIAL RELATIONSHIP Paul Morris HBRK Associates, Inc SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Hyperion Air, LLC SOUTHERN FINANCIAL RELATIONSHIP Paul Morris JEGE, Inc SOUTHERN FINANCIAL RELATIONSHIP EFTA01407758 Paul Morris Neptune, LLC SOUTHERN FINANCIAL RELATIONSHIP Paul Morris SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Zorro Development Corp. SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Gratitude America SOUTHERN FINANCIAL RELATIONSHIP Paul Morris EFTA01407759 Please let me know if you have any questions and please let me know when this has been completed. Best, Armen fcid:[email protected] Armen Brash Director Deutsche Asset & Wealth Management 345 Park Avenue, 10154-0004 New York, NY, USA Tel. Mobile fcid:[email protected] EFTA01407760