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sd-10-EFTA01414537Dept. of JusticeOther

EFTA Document EFTA01414537

Subject: RE: Remediation 2015-2016 ACO queries.xlsx [I] From: Christopher Whyton < 1= > Date: Wed, 01 Feb 2017 08:45:17 -0500 To: Vahe Stepanian Cc: Isabel-A Gonzalez Stewart Oldfield Alastair Mackinlay lain Macara < Thanks Vahe, ok noted. lain — FYI. From: Vahe Stepanian Sent: 01 February 2017 13:42 To: Christopher Whyton Cc: Isabel-A Gonzalez; Stewart Oldfield; Alastair Mackinlay Subject: RE: Remediation 2015-2016_ ACO queries.xlsx [I] Classification: For internal use only Hi C

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Dept. of Justice
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sd-10-EFTA01414537
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Subject: RE: Remediation 2015-2016 ACO queries.xlsx [I] From: Christopher Whyton < 1= > Date: Wed, 01 Feb 2017 08:45:17 -0500 To: Vahe Stepanian Cc: Isabel-A Gonzalez Stewart Oldfield Alastair Mackinlay lain Macara < Thanks Vahe, ok noted. lain — FYI. From: Vahe Stepanian Sent: 01 February 2017 13:42 To: Christopher Whyton Cc: Isabel-A Gonzalez; Stewart Oldfield; Alastair Mackinlay Subject: RE: Remediation 2015-2016_ ACO queries.xlsx [I] Classification: For internal use only Hi C

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Subject: RE: Remediation 2015-2016 ACO queries.xlsx [I] From: Christopher Whyton < 1= > Date: Wed, 01 Feb 2017 08:45:17 -0500 To: Vahe Stepanian Cc: Isabel-A Gonzalez Stewart Oldfield Alastair Mackinlay lain Macara < Thanks Vahe, ok noted. lain — FYI. From: Vahe Stepanian Sent: 01 February 2017 13:42 To: Christopher Whyton Cc: Isabel-A Gonzalez; Stewart Oldfield; Alastair Mackinlay Subject: RE: Remediation 2015-2016_ ACO queries.xlsx [I] Classification: For internal use only Hi Chris — we are actually offboarding Southern Financial in GM. Let us know if you need anything else. Best, Vahe From: Christopher Whyton Sent: Wednesday, February 01, 2017 8:38 AM To: Vahe Stepanian Cc: Isabel-A Gonzalez Subject: RE: Remediation 2015-2016_ ACO queries.xlsx EFTA01414537 Hi Vahe Hope you're well. I'm working on the ACO workstream in GM and have been made aware of the below client (in yellow) that is due for KYC remediation but doesn't have an ACO assigned. Are you able to propose an ACO? Isabel (cc'd) needs to feed the ACO name back to COB/outreach fairly urgently as the stance taken is that any clients without an ACO should be moved to the red list for offboarding. Thanks Chris From: Isabel-A Gonzalez Sent: 01 February 2017 11:51 To: Christopher Whyton Subject: RE: Remediation 2015-2016_ ACO queries.xlsx Hi Chris, I have done a bit of digging on this. As per below table, two of this names were indeed included in the Phase I of the Trading Outreach. The other 2 may have happen offline via Iain. Please see below the details I have been able to extract: Trading Outreach Output EFTA01414538 CLIENTID LEGAL NAME GM Sales Sponsor for Outreach In trading outreach Phase i ACO suggested Sales suggested Person Making Suggestions 1000040765 William Beaumont Hospital 1004688558 Proven Wealth Limited Adrienne Coyle yes Alex Giannou Adrienne Coyle Bruce Harkness, EM 1007406812 EFTA01414539 Southern Financial, LLC Vahe Stepanian 1008346243 Tradition SEF, Inc. Olivier Pariente - TCG Yes Olivier Pariente - TCG Matt Barnett (TCG) Matt Barnett (TCG) My suggestions are: #1 - reach out to Anthony. He is very responsive #2 — reach out to ACO, and Bruce. #3 — reach out to Vahe #4 — reach out to Matt. Thanks. EFTA01414540 Kind regards, Isabel. Isabel Gonzalez ICG Sales COO Team Deutsche Bank AG, Filiale London Winchester House, 1 Great Winchester Street I EC2N 2DB London From: Christopher Whyton Sent: 01 February 2017 09:37 To: Isabel-A Gonzalez Subject: RE: Remediation 2015-2016_ ACO queries.xlsx Hi Isabel The first 3 below were not part of the debt trading outreach. Do you recall how you were made aware that trading wishes to keep? The person in the bottom one doesn't exist in the directory so I'll need to ask around in the even they've left. LEGAL NAME GM Sales Sponsor for Outreach 1000040765 EFTA01414541 William Beaumont Hospital 1004688558 Proven Wealth Limited Adrienne Coyle 1007406812 Southern Financial, LLC Vahe Stepanian 1008346243 Tradition SEF, Inc. Olivier Pariente - TCG Thanks Chris From: Isabel-A Gonzalez Sent: 31 January 2017 17:49 To: Christopher Whyton Subject: Remediation 2015-2016_ ACO queries.xlsx Hi Chris, As requested please find attached the names and below the statuses to be investigated: EFTA01414542 Internal entities — These accounts require remediation AND an ACO to sign off the remediation. o Can we off-board these? o If not, please provide an the ACO or get confirmation from AFC/ COB these account don't require ACO attestation Data Issues — idem CIB Claimed — These have been deemed off-boards unless you can find an ACO or say otherwise Thanks. Kind regards, EFTA01414543

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