EFTA Document EFTA01417593

Subject: RE: Assistance Required in Resolving Rejection Points KYC # - 01977700 [I] From: Vijay-A Sawant <MIE > Date: Tue, 11 Sep 2018 09:59:49 -0400 To: Bradley Gillin Stewart Oldfield Cc: Richard Iarossi Mayur Rathod Hi Brad, As discussed, following is the excerpt regarding treatment of major donors in Foundation entities as per our latest KOP — As discussed, this donation was received in 2015, and there have been 2 KYC cases approved since then (2016 & 2017) which did not identify this donor, so we are checking internally on why is this EDR required now? I am waiting for feedback from Daphne and I will get back to once I hear from her on this, thanks. Kind Regards, {cid: } 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. Mobile EFTA01417593 From: Bradley Gillin Sent: Tuesday, September 11, 2018 6:23 PM To: Vi'a -A Sawant < ; Stewart Oldfield Cc: Richard Iarossi ; Mayur Rathod Subject: RE: Assistance Required in Resolving Rejection Points KYC # - 01977700 [I] Classification: For internal use only Hi Vijay, Please send the KYC policy, specifically for a Foundation, regarding below. Thanks. Kindly confirm whether this donation constitutes 10% or more of the Gratitude's total assets? If yes, we would require constitutional docs for BV70, LLC (i.e constitutional docs, formation docs, ownership details, etc) Regards, Brad fcid:[email protected] Bradley Gillin Vice President Deutsche Bank Wealth Management 345 Park Avenue, 24th Fl New York, NY 10154 Tel. Fax EFTA01417594 Securities offered through Deutsche Bank Securities Inc. From: Vijay-A Sawant Sent: Monday, September 10, 2018 8:21 AM To: Stewart Oldfield Cc: Bradley Gillin ; Mayur Rathod Subject: Assistance Required in Resolving Rejection Points KYC # - 01977700 Importance: High Richard Iarossi Good Morning Stewart, We are in receipt of following rejection points for Gratitude America Ltd, see my comments in red fonts - Your KYC has been rejected. Case #: 01977700 Relationship: SOUTHERN FINANCIAL RELATIONSHIP Customer Name: Gratitude America Ltd Customer Number: 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. — As per attached Form 990 (from 2015), we can see that entity BV70, LLC donated $10 million to Gratitude. Kindly confirm whether this donation constitutes 10% or more of the Gratitude's total assets? If yes, we would require constitutional docs for BV70, LLC (i.e constitutional docs, formation docs, ownership details, etc) 2) Please provide ExCo approval as this is now an EDR. — Please provide since this is an EDR. 3) Please provide the FinCEN form. — If BV70, LLC is to be considered as UBO EFTA01417595 as per point 1, then revised CDD form required with updated section c. To view the KYC click here https://dbforcepb.my.salesforce.com/- 5000e00001N005H Thanks & Regards {cid: } Vijay Sawant KYC Case Representative Deutsche CIB Centre Private Limited Deutsche Bank Group Wealth Management Bl, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway Goregaon East, Mumbai - 400063 , India Tel. Mobile {cid: } Mayur Rathod KYC Case Representative Deutsche CIB Centre Private Limited Wealth Management Floor 1, Bl, DB Centre Mumbai Nirlon Knowledge Park, Western Express Highway, Goregaon East, Mumbai 400063 India Tel.: Email: EFTA01417596