EFTA01356744.pdf

KYC Print Page 34 of 35 M. Case Comments Created By Date Comments Uformer name. Jose Aionso 12..3i 118 11 57 AM Aromatiss S.A.S is 100% owned by Cosmo International Fragrances, S L Cosmos Enterprises SLU - The change took place on 7/2612018. AFC has accepted the research attached for .ban Pablo Godoy Fajardo. The date format is Dimitra Manley 1214/118 8:21 AM listed as 03/12/2018. However, this research was conducted and attached to the KYC on 12/3/2018. This KYC serves as an EDR for Aromatiss S.A.S (herein referred to as accountholder), an existing Wealth Management client since April 2018. This EDR included the following changes: (I) The addition of 3 UBOs, as beneficiaries of the Opus Futurus Foundation. (2) Update to loan signatories (per attached borrowing resolution). (3) Legal name change for an 180: Cosmos Enterprises SLU changed Its name to Cosmo International Fragrances, S.L.U. Risk Factors Include: • PEP Relationship: The UBOs are Relatives or Close Associates (RCAs) of a PEP due to their relationship with Gonzalo Aguirre Arria. one of the founders of Coordinadora National de I ndependientes, a political party established in Peru. Mr. Awiz is married to Janine Marion Belmont Dauelsberg. The PEP status was previously escalated (see attached escalation) • Source of Wealth (SOW )Industry: Juan Fernando Belmont Anderson (UBO) created Corporacion Yanbal International, a cosmetics company in Latin America. SOW Verification has been obtained. Dimitra Manley 12/4/118 10:06 AM • Complex Structure: The ownership structure consists of multiple intervening layers. Below are the reasons why we are comfortable with approving this KYC: • Information and supporting documents required by our AML Policy were provided and reviewed; and as a result, we have an understanding of the structure of the accountholder, its purpose. the purpose of the account and expected activity. • The SOW was sufficiently detailed and appears plausible. Internet searches provided enough nformation to support the wealth for the prospective account holders and UBOs. Below are the risk factors associated with the accountholder- • Our review did not identify any red flags and thus there was no need to escalate this case further. • Due diligence searches were performed on all key and the names searched were not on any sanctions lists • The UBOs and a legal rep/signatory appeared in the ICIJ Database as being linked to Paradise Papers. However, the appearance of the name in ICIJ database alone does not require escalation if there is no other negative information that presents significant or material Peputational risk. There was no adverse media on the account holder. UBOs, or legal reps to warrant further escalation. The August 2018 Fircosoft alert generated for Jesus Armando Lema Hanke is the same alert 8:25 Am generated in April 2018. when the account holder was on-boarded. BLAFC-WM previously Dimitra Manley 1214/118 reviewed and cleared the alert. The prior clearance (from April 2018) is attached to the KYC and covers the current alert. ONSHORE APPROVALS Client Facing Professonal (CFP) -Os e A c^sc ,Signature) 12/1/2018 Jose konso Office Director/Business Head Eva Pace ,Signature) 12/3/2018 Eva Pace Regional Office Director (Signature) AML Business Risk (Signnie) AML Compliance: (Signature) https://dbforcepb.my.salesforce.com/serylet/servlet.Integration?lid IN30000000D9Di&... 12/19/2018 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042774 CONFIDENTIAL SDNY_GM_00188958 EFTA01356744