Epstein Secrets

ML controls of new client adoption processes instituted by Global Banking as well as escalation processes for high risk accounts as defined by DBUS AML Policy. The File Review will focus on the functional aspects of the required new client adoption processes surrounding AML compliance including, Customer

Appendix D- Global Banking Assessment 1.1 Quarterly Global Banking AML/NCA File Assessment - Overview The DBUS AML Compliance Unit ('AML Unit") will conduct Quarterly AMLINCA File Review Assessments ("File Review") on ten (10) randomly selected new client adoptions files affecte

ese 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

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

sess the AML aspects of New Client Adoption processes instituted by CRE as well as review for escalation for higher risk accounts as defined by DBUS AML Policy. The File Review is applicable to new client adoptions executed in the CRE Loan Origination and CRE Syndicated Loan desks: excluded from the File R

Appendix C - CRE Assessment 1.1 Quarterly CRE AML/NCA File Assessment - Overview The DBUS AML Compliance Unit ("AML Unit") will conduct Quarterly AMUNCA File Review Assessments ("File Review") on ten (10) randomly selected New Client Adoptions files affected

nt adoption processes instituted by Global Markets as well as escalation processes for high risk accounts and Specified Borrowers as defined by DBUS AML Policy and the Term Asset-Backed Securities Loan Facility ("TALF") Requests Desktop Procedure (CAG). The File Review will focus on the functional aspects

Appendix B - TALF Assessment 1.1 Monthly Term Asset-Backed Securities Loan Facility AML/NCA File Assessment - Overview The DBUS AML Compliance Unit ("AML Unit') will conduct Monthly AML/NCA TALF Borrower File Review Assessments ("File Review') on five (5) randomly selected new client adoptions f