Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] From: Nicholas Hislop Date: Tue, 22 May 2018 04:42:27 -0400 To: Kareen Johnson < Cc: Simon Nall < Martin Zeman Daniel-A Klyashtorny Nina Tona Xavier Avila Davide-A Sferrazza AMLUK Reviews Devshiji Odedra Ian Salters Ricky-x Patel Jesse-J Cruz Zack Bunimovich Jonathan Whittle James Gladwin Classification: For internal use only From what I can see in the audit, the profile was loaded, and has actually been through the workflow post loading. I can only assume that this is a case of the profile being out of date or not complete (ie KYC missing, this was originally a UP in London migration and few Ups were found to have KYC). From: Kareen Johnson Sent: 22 May 2018 02:35 To: Nicholas Hislo Cc: Simon Nall ; Martin Zeman a; Daniel-A Klyashtorny ; Nina Tona Avila ; Davide-A Sferrazza ; AMLUK Reviews ; Devshiji ; Ian Salters ; Ricky-x ; Jesse-J Cruz ; Zack ; Jonathan Whittle James Gladwin <a> Escalation: ONB-1135648 / LKYCGB-160049 / Southern Odedra Patel Bunimovich a Subject: Re: LLC [I] Financial EFTA01400073

The concern is not because of the risk level and escalation, but the fact there was no previous GB review when products have been added since 2014. Kareen Johnson On May 21, 2018, at 12:07 PM, Nicholas Hislop wrote: Classification: For internal use only Hi Kareen, Is this not because the client is High risk and therefore all extensions are routed to AFC, and/or the Global KYC was out of date? Therefore the completion of the global triggered the local requests for review? From: Kareen Johnson Sent: 21 May 2018 12:34 To: Nicholas Hislo Cc: Simon Nall ; Martin Zeman Daniel-A Kl ashtorny ; Xavier Avila ; AMLUK Reviews Odedra >; Ian Salters Patel Jesse-J Cruz Bunimovich ; Jonathan Whittle >; James Gladwin <E > Re: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Subject: LLC [I] Good day Nick - ; Nina Tona ; Davide-A Sferrazza ; Devshiji ; Ricky-x ; Zack Financial We have an issue here where in dbCAR this relationship did not reflect an old GB review date. We can see in the master profile that the relationship EFTA01400074

was created several years ago under DBAG, but now when extending for a new product, the review was missing completely. The file was escalated to AML for review and approved . This action triggered a GB review date for the very first time. Is it possible this was a merger issue? Please let me know if your team could take a look and if additional information is needed. Thank you! Kareen Johnson On May 18, 2018, at 12:11 PM, James Gladwin a wrote: Classification: For internal use only Hi Simon, Absolutely, quite simply: i. Our Jacksonville CDS colleague, Kareen Johnson, will be reaching out to the dbCLIENT merger team to query the status/success of the KCP merge from dbCLIENT to dbCAR a. @Kareen, it would be great if I could be CC'd in to your correspondence so that AFC can be advised accordingly ii. Nina Tona from business side will be providing myself with the list of KCP clients so that I can conduct a sanity sample check Both colleagues have been instrumental in assisting with this extension request. I will provide feedback on the above in due course. EFTA01400075

Kind regards, <image001.gif> James Gladwin AFC Business Advisory Anti-Financial Crime DBOI Global Services (UK) Limited 5 Brindley Place, Birmingham, B1 2JB, United Kingdom Email: P Please consider the environment before printing this email From: Simon Nall Sent: 16 May 2018 15:26 To: James Gladwin Martin Zeman <a> Cc: Kareen Johnson ; Daniel-A Klyashtorny <daniel- ; Nina Tona ; Xavier Avila ; Davide-A Sferrazza ; AMLUK Reviews ; Devshiji Odedra Ian Salters ; Ricky-x Patel Jesse-J Cruz < ; Zack Bunimovich Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] Classification: For internal use only James EFTA01400076