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

ML Policy. The File Review will focus on the functional aspects of the required new client adoption processes surrounding AML compliance including, Customer Identification Program elements (Notification, Identification, Verification, Retention) as well as verification documentation, as appropriate. The File Review will also i

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

tizationl. The File Review will focus on the functional aspects of the required new client adoption processes surrounding AML compliance including, Customer Identification Program elements (Notification, Identification, Verification, Retention) as well as verification documentation, as appropriate. The File Review will also i

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

ure (CAG). The File Review will focus on the functional aspects of the required new client adoption processes surrounding AML compliance including, Customer Identification Program elements (Notification, Identification, Verification, Retention) as well as verification documentation, as appropriate. The File Review will also i