Subject: FW: ACTION REQUIRED: Issue related to ACUs [I] From: Paul Morris ‹ > Date: Tue, 27 Oct 2015 11:13:13 -0400 To: Amanda Kirby Jj Litchford Classification: For internal use only Hi, did we finish these? Paul Morris Managing Director Deutsche Bank Private Bank Office: Cell: From: Armen Brash Sent: Tuesday, October 13, 2015 6:37 PM To: Paul Morris; Amanda Kirby Subject: ACTION REQUIRED: Issue related to ACUs [I] Classification: For internal use only Paul and Amanda, 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 exempting high risk clients with only EFTA01475446
deposit accounts under $250K from the ACU when it should not be—the code will be fixed ASAP, but in the meanwhile, while the ACUs listed below don't appear as overdue, they must be completed by year end. Customer Name Customer # Relationship Primary Officer ACU Completed Date Butterfly Trust SOUTHERN FINANCIAL RELATIONSHIP Paul Morris The 2007 Jeffrey E. Epstein Insurance Trust #3 SOUTHERN FINANCIAL RELATIONSHIP Paul Morris New York Strategy Group, LLC SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Plan D, LLC EFTA01475447
SOUTHERN FINANCIAL RELATIONSHIP Paul Morris HBRK Associates, Inc SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Hyperion Air, LLC SOUTHERN FINANCIAL RELATIONSHIP Paul Morris JEGE, Inc SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Neptune, LLC SOUTHERN FINANCIAL RELATIONSHIP Paul Morris EFTA01475448
SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Zorro Development Corp. SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Gratitude America SOUTHERN FINANCIAL RELATIONSHIP Paul Morris Please let me know if you have any questions and please let me know when this has been completed. Best, EFTA01475449
Armen fcid:[email protected] Armen Brash Director Deutsche Asset & Wealth Management 345 Park Avenue, Tel. Mobile Email 10154-0004 New York, NY, USA Fax fcid:[email protected] EFTA01475450

