From: Vijay-A Sawant
Sent: 9/11/2018 9:59:49 AM
To: Bradley Gillin [-1; Stewart Oldfield
CC: Richard larossi [ ]; Mayur Rathod
Subject: RE: Assistance Required in Resolving Rejection Points KYC # --
Importance: High
Hi Brad,
As discussed, following is the excerpt regarding treatment of major donors in Foundation entities as per our latest KOP —
For a charity (whether constituted as a trust, foundation, corporation or otherwise), we will regard founding
donors contributing more than 25% of the initial funds (more than 10% for high risk) as UBOs. together with
significant donors responsible for more than 25% of annual donations — more than 10% for high risk) where
we become aware of them. Where the long-standing existence of the charity demonstrates its present wealth
not to be reliant on that contributed by a deceased founding donor, then this should be evidenced and
documented and the founding donor should not be treated as UBOs.
As discussed, this donation was received in 2015, and there have been 2 KYC cases approved since then (2016 & 2017)
which did not identify this donor, so we are checking internally on why is this EDR required now? I am waiting for
feedback from Daphne and I will get back to once I hear from her on this, thanks.
Kind Regards,
Vijay Sawant
KYC Case Representative
Deutsche CIB Centre Private limited - Deutsche Bank Group
Wealth Management
81, DB Centre Mumbai, Nirlon Knowledge Park, Western Express Highway
Goregaon East Mumbal 400063, India
Tel.
Mobile
From: Bradley Gillin
Sent: Tuesday, September 11, 2018 6:23 PM
To: Vijay-A Sawant <vijay-a.sawant@db.com>; Stewart Oldfield <stewart.oldfield@db.com>
Cc: Richard larossi <richard.iarossi@db.com>; Mayur Rathod <mayur.rathod db.com>
Subject: RE: Assistance Required in Resolving Rejection Points KYC tf -
Classification: For Internal use only
Hi Vijay.
Please send the KYC policy. specifically for a Foundation, regarding below. Thanks
Kindly confirm whether this donation constitutes 10% or more ofthe Gratitude's total assets? Lives, we would require constitutional
docsfor B1'70, LLC (i.e constitutional docv, formation dots, ownership details. etc)
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0066830
CONFIDENTIAL SDNY_GM_00213014
EFTA01372920