EFTA01459855.pdf

From: Amanda Kirb Sent: 3/7/2016 10:50:49 AM To: Melisa Venegas Mildred Hernandez ; Melinda Roy CC: Paul Morris Armen Brash Subject: RE: ACTION REQUIRED: Issue related to ACUs III Classification: For Internal use only Melinda - FYI Best, Amanda Kirby Amanda Kirby Deutsche Bank Trust Company Americas Deutsche Bank Wealth Management 345 P Av 154-0004 New York, NY, USA Tel. Fax Email Racial...1v Peep:con Securities offered through Deutsche Bank Securities Inc. From: Melisa Venegas Sent: Monday, March 07, 2016 10:49 AM To: Amanda Kirby; Mildred Hernandez Cc: Paul Morris; Armen Brash Subject: ACTION REQUIRED: Issue related to ACUs [I] Classification: For internal use only All, As you may know, per the AML Procedures manual, certain clients are excluded from ACUs. An issue has been identified in dbforce where High Risk clients are given an ACU Auto Exemption for Retail Banking, however, per Policy, this exception does NOT apply to High Risk clients. Unfortunately, the code in dbforce is exempting high risk clients with only deposit accounts under $250K from the ACU when it should not be —the code will be fixed, but in the meanwhile, while the ACUs listed below don't appear as overdue, they must be completed. GCIS Customer Customer Name Relationship PO tr JEGE, LLC SOUTHERN FINANCIAL RELATIONSHIP Paul Morris CONFIDENTIAL — PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0 120588 CONFIDENTIAL SDNY_GM_00266772 EFTA01459855