EFTA01357150.pdf

; Zack Bunimovich u ject: : sca atton: ONB-1135648 / LKYCGB-160049 / Southern Financial Ut III Classification: For intemal use only James Thank you for the update Can you confirm the plan for the feedback on 3A below Kind Regards Simon Nall <image001.gif> Deutsche Bank Email From: James Gladwin Sent: 16 May 2018 15:19 To: Martin Zeman Cc: Kareen Johnson ; Daniel-A Klyashtorny Nina Tona ~111~-; Xavier Avila Davide-A Sferrazza AMLUK Reviews >; Devshiji Odedra a; lan Salters >; Simon Nall ; Ricky-x Patel >; Jesse-1 Cruz >; Zack Bunimovich Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC (IJ Classification: For intema) tias only Hello all, After liaising with Global CDS teams and specialist colleagues, UK AFC have identified the key barriers and now duly approved the Extension request. am happy to confirm that a BRG approval will NOT be necessary for this Extension. For the sake of clarity and knowledge sharing it would be prudent to share a brief summary of the cause and resolution of such. I am more than happy to discuss and expand further via telephony should it be requested. i. Extension request was received by UK AFC and upon our initial review of the request it was apparent that there was no UK adoption within the dbCAR system, therefore AFC queried the requirement of a BRG review ii. Post investigation identified UK products had been booked WITHOUT a UK adoption — a never seen before scenario iii. Escalations to local policy colleagues and global CDS teams had also never seen such a scenario. Two cause theories were presented; CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0043518 CONFIDENTIAL SDNY_GM_00189702 EFTA01357150