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: James Gladwin Sent: 11 May 2018 18:44 To: Martin Zeman ; Jesse-J Cruz Cc: Kareen Johnson < ; Daniel-A Klyashtorny <daniel- ; Nina Tona ; Xavier Avila ; Davide-A Sferrazza -; AMLUK Reviews • ; Devshiji Odedra Ian Salters ; Simon Nall ; Ricky-x Patel Subject: RE: Escalation: ONB-1135648 / LKYCGB-160049 / Southern Financial LLC [I] ; Zack Bunimovich Classification: For internal use only Hello all, I have had the pleasure with speaking directly with Martin and colleagues to assist UK AFC with this KCP Extension. UK AFC are kindly in receipt of the KCP GM policy dated June 2017 (duly noted that this is currently under review), this document has proved useful in giving context to the UK GM product nexus with solely a US booking. EFTA01400115

Due to the local UK time, I will be discussing KCP Extensions with my management on Monday as to best understand and process such requests in the future. I truly appreciate the time and knowledge that has been shared and look forward to our conversations next week as to support each other. Many thanks all, {logo} 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: 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 EFTA01400116

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. @Martin I will keep you updated on the progress made. Many thanks all, {logo} James Gladwin AFC Business Advisory EFTA01400117