P Please consider the environment before printing this email From: James Gladwin Sent: 10 May 2018 09:47 To: Martin Zeman ; Jesse-J Cruz Cc: Kareen Johnson < ; Daniel-A Klyashtorny <daniel- ; Nina Tona ; Xavier Avila ; Davide-A Sferrazza ; AMLUK Reviews ; Devshiji Odedra Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] ; Zack Bunimovich Classification: For internal use only Hello all, Do we have BRG approval for this? This is appears to be a cross-jurisdictional adoption from DBSI to II AG, furthermore, the LRD for the US is 2016 and does not appear to be in the Remediation pipeline? For Extensions to be approved, AFC UK require: i. BRG approval to consider cross-jurisdictional approvals which result in newly booked High Risk clients ii. The file to be within NRD date and if not, must be within the Remediation pipeline — of which it appears it is neither @CDS colleagues, Please consider the above points, I am happy to further explain on the phone to assist our business colleagues & clients expectations. EFTA01400081

@Martin I will keep you updated on the progress made. Many thanks all, <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: Martin Zeman Sent: 08 May 2018 20:27 To: Zack Bunimovich ; AMLUK Reviews >; Jesse-J Cruz ; James Gladwin Cc: Kareen Johnson < ; Daniel-A Klyashtorny <daniel- ; Nina Tona ; Xavier Avila ; Davide-A Sferrazza Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] EFTA01400082

Classification: For internal use only James — responding to your questions below. The extension is permanent. Southern Financial LLC trade global macro and are looking to buy CDX IG payer spreads as a hedge for their overall equities and fixed income portfolio they trade with II. The initial size is around $100M. Please call me if you need any more details. This is a priority for our desk. Thank you. From: Zack Bunimovich Sent: Tuesday, May 08, 2018 12:24 PM To: AMLUK Reviews James Gladwin Cc: Kareen Johnson ; Martin Zeman Jesse-J Cruz <jesse- ; Daniel-A Kl ashtorny <daniel- ; Nina Tona Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] Classification: For internal use only +Nina From: Zack Bunimovich Sent: Tuesday, May 08, 2018 10:21 AM To: AMLUK Reviews James Gladwin Cc: Kareen Johnson ; Martin Zeman Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] ; Jesse-3 Cruz <jesse- ; Daniel-A Kl ashtorny <daniel- Classification: For internal use only EFTA01400083