EFTA Document EFTA01425014

Subject: RE: MR / LR remediation - your portfolio From: Maximilian Taut Date: Thu, 24 Jan 2019 To: Stewart Oldfield Cc: Bradley Gillin < Emily Craig Corinna-A Relic en Dear Stewart, My name is Maximilian, I work closely with Corinna Reibchen and Dian Stoianov from passcon. I just wanted to follow up with you quickly regarding the LR/MR remediation project. We've updated your portfolio with the client status and due dates (please see attached). Please note that the clients in green have been approved, while those in yellow have been set to Pending Exclusion due to account closure/client exiting as indicated previously. I'd like to see if we can set up another call to discuss the rest of your clients with particular emphasis on if any more are closing or being exiting and your client outreach preferences. Would you have time for a quick chat next week? I'm quite flexible and happy to schedule at your convenience. Thank you in advance and I look forward to speaking with you. Kind regards, Maximilian EFTA01425014 fhttps://brandportal.intranet.db.com/img/modules/logo.gifl Maximilian Taut External I Manager I passcon GmbH Deutsche Bank Trust Company, National Association Deutsche Bank Wealth Management 5022 Gate Parkway, Suite 400 Jackso USA Phone Mobil Email From: Stewart Oldfield Sent: Tuesday, November 27, 2018 5:22 PM To: Corinna-A Reibchen <[email protected]> Subject: RE: MR / LR remediation - your portfolio Tuesday the 4th is open 10-12 and 2-5. Thanks From: Corinna-A Reibchen Sent: Tuesday, November 27, 2018 4:16 PM To: Stewart Oldfield ‹ > Subject: RE: MR / LR remediation - your portfolio Hello Stewart, Thank you for your feedback. EFTA01425015 Can we talk on Tuesday the upcoming week? When would you have time? Thank you. Best, Corinna From: Stewart Oldfield Sent: Monday, November 26 2018 6:40 PM To: Corinna-A Reibchen Cc: Bradle Gillin < ; Richard Iarossi Su ject: : remediation - your portfolio Corinna, thanks for this. Happy to discuss whenever you like. I'm open tmw from 2-4 and most of the rest of week between 10 and 4. Thanks From: Corinna-A Reibchen Sent: Tuesday, November 20, 2018 7:25 PM To: Stewart Oldfield Subject: MR / LR remediation - your portfolio Dear Stewart, EFTA01425016 My name is Corinna Reibchen. I am the CEO of passcon LLC, a consulting firm specialized in KYC for the banking sector. Passcon has been hired by Deutsche Bank Wealth Management U.S. to support the high risk remediation in 2018 as well as low and medium risk remediation in 2019. As per Thomas Klemm's email from Friday November 16th, we have compiled all relevant data points from the static data systems (like dbForce and GMIS) to provide you with an overview of your individual client portfolio in scope for the 2019 low and medium risk remediation. Please find attached your individual client portfolio which will be part of this remediation. What are we doing for you? Our primary goal is to perform the low and medium risk remediation as seamlessly as possible for you and your clients. For this reason, we are currently discussing integrating client outreach into the KYC process, which will be conducted by passcon's well-trained KYC Analysts. We see this as an exciting new development in the KYC process, as it will allow you to focus on developing your client relationships, while we take ownership over retrieving documents to complete the cases. We can assure you that the client outreach will be client-oriented and highly professional, giving you peace of mind that your clients will be in good hands. I would like to give you the following details of the process: Detailed overview of your individual client portfolio We will compile your individual client portfolio based on the existing information in the static data systems (as noted above). We will contact you to discuss the portfolio especially with regards to potential exits or where you would like to reach out to the clients due to an expected complexity or EFTA01425017 sensitivity. That way, all stakeholders are on the same page. Client Outreach Before we reach out to any of your clients we will discuss with you the best way to contact the clients. Please specify those clients that you would like to reach out to directly (max. 20 %), in the file attached, Column P. You will always be copied in and all ACO-confirmed clients will be contacted during the KYC process by passcon in case of missing documents or information. The initial timeframe to deliver the requested information will be 4 weeks. After reaching the 4 week milestone without getting the necessary information, two reminders will be sent out every two weeks. In case of unresponsive clients an agreed escalation process from passcon to you will be followed to consider the exit option in the worst case. Please note that before we reach out to the clients we will discuss the missing information first of all with you and will then only reach out to the client with the agreed remaining outstanding required information. To provide comfort to you on our experience and the feasibility of our approach, we will agree on certain clients with you to conduct a pilot on this outreach. Reporting and MI The progress will be monitored and tracked by passcon. Passcon will deliver an update for your individual client portfolio every two weeks. Further reports on a higher level will be delivered to the KYC SteerCo more frequently. I kindly request you in the first step to review your individual client portfolio and share your feedback as soon as possible. We will schedule a call with you shortly to discuss further details and next steps. Your support is highly appreciated, and we are excited to begin collaborating with you to achieve a successful remediation in 2019! EFTA01425018 Please do not hesitate to contact us in case of any questions in the meantime. Many thanks and kind regards, Corinna Corinna Reibchen CEO I passcon LLC fcid:[email protected] 100 Park Avenue I 10017 New York I USA Mobile I passcon.com XING I Linkedln EFTA01425019