Deutsche Bank
Compliance
/
RECOMMENDATION
The Dormant account rule cannot restrict specific transaction types (i.e. low risk transactions like internal
transfers) to be excluded from the process. So, a weighted methodology for weekly/monthly sampling
based on underlying transactions and risk class has been established.
No new recommendations.
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CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0062906
CONFIDENTIAL SDNY_GM_00209090
EFTA01370242