EFTA01356511.pdf

From: Oliver Esslinger Sent: 5/30/2019 11:36:52 AM To: Ian Salters Funda Bozkurt Bill King ); Kimberly Hart ; Janice Franklin Maria Pedulla ( Subject: Managed Exit account handling Attachments: Managed Exits.xlsx Location: 880884540439, PIN 7303# Start: 6/5/2019 1:00:00 PM End: 6/5/2019 1:30:00 PM Show Time As: Tentative Recurrence: (none) Term Definition PA Review of client account activity to establish open obligations which prevent onboard Checks/Review A process state for client entities identified for offboarding but have open obligations which Managed Exit prevent process completion The process of sending a client notification to terminate the contractual relationship at the end Notification of a defined notice period In Closure The process of closing DB transactional system accounts representing the impacted client entity A count of client entities which have completed all offboarding process stages, and are inactivated through to KYC Records - classified as 'Full' Oftboard when evidenced, complete Ofiboarded removal of client entity from all businesses & jurisdictions inclusive of all tech platforms. Applied to all DB adoption entities globally. Below is how the CIB process works: • The client is marked to be Off-Boarded but cannot be as there is an outstanding obligation (i.e. loan or position) with the client • Client has been deemed to be KYC relevant by Business • Managed Exit team searches in paid/public sources for the 4 below attributes • Proof of Existence • Legal Representatives • Ownership/IBO • Identity (ID)/Nationality & Source of Wealth (SOW) (Net Worth & source from where it is acquired) • If not found, 2 notification letters are dispatched to the client seeking information • Business is not involved in the sourcing of data • Case is enriched • KYC is collected on a best effort basis and if all 4 attributes cannot be sourced it is notated in the file • Account will be quarantined until the obligation/position expires • ACO signs off on the Managed Exit CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042401 CONFIDENTIAL SDNY_GM_00188585 EFTA01356511