EFTA01372643.pdf

AMUNCA File Assessment — Overview The DBUS AML Compliance Unit ("AML Unit") will conduct AMIJNCA File Review Assessments ("File Reviews") for the following business lines and/or account types on either a monthly or a quarterly basis: • Global Markets, Client Adoption Group (monthly)— see Appendix A • Global Markets, TALF specific (monthly) — see Appendix B • Commercial Real Estate (quarterly) — see Appendix C • Global Banking (quarterly) — see Appendix D • MortgagelT, Broker specific (quarterly) — see Appendix E • MortgagelT (quarterly) — see Appendix F The Appendices (A through F) detail requirements for the business lines / account types. The reviews will evaluate the adequacy of the CIP/AML relevant processes performed. These monthly/quarterly File Reviews are designed to assess controls instituted as well as any escalation for higher risk accounts as defined by DBUS AML Policy. CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0066428 CONFIDENTIAL SDNY_GM_00212612 EFTA01372643