From: Melinda Roy Sent: Monday, March 07, 2016 10:56 AM To: Jj Litchford Subject: FW: ACTION REQUIRED: Issue related to ACUs [I] Classification: For Internal use only See below From: Paul Morris Sent: Monday, March 07, 2016 10:55 AM To: Melisa Venegas Cc: Armen Brash; Melinda Roy Subject: RE: ACTION REQUIRED: Issue related to ACUs [I] Thank you we will get it done. Thanks Original Message From: Melisa Venegas Sent: Monday, March 07, 2016 10:49 AM Eastern Standard Time 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 JEGE, LLC LSJE, LLC Relationship SOUTHERN FINANCIAL RELATIONSHIP SOUTHERN FINANCIAL RELATIONSHIP PO Paul Morris Paul Morris Please let me know if you have any questions and please let me know when this has been completed. Thank you. Regards, Melisa Venegas CONFIDENTIAL — PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0 120604 CONFIDENTIAL SDNY_GM_00266788 EFTA01459863