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Corpus: 1990-03-17 – 2025-12-01

January 2018

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EFTA01399077Set 10

2018-01-0370p4,378w

Reverse Solicitation — Scenarios 1 Third Country Firms Requirements to interact with EEA Clients 2 3 Background 1. 2 Reverse Solicitation Controls (lead/prospect) EEA Criteria & EEA Country List Appendix A — EEA ... clients/accounts: The EEA is not a target market for WM Americas. On-boarding new EEA clients or opening new EEA accounts will be limited (on a case by case basis ... trigger MiFID II requirements. WM Americas is not triggering branch/licensing requirements as long as EEA clients are exclusively served on a reverse solicitation. The current BaFIN exemption permits DBTCA

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01399077.pdf

EFTA01399156Set 10

2018-06-125p1,283w

Table: Account Opening Review Group Product Type WM NOC Deposits, Custody, DPM and Trust EEA client identified on dbforce Customer page, 'EEA Country' field. For each new account, Please check ... marked as EEA in Dbforce on customer page (EEA Client type = "Retail or "Professional") and EEA country If EEA country is Germany, proceed with existing requirements (MIFID II Regulation). Reverse ... Solicitation Controls (Excluding German Clients) Account Opening Review Group to ensure EEA Client Declaration form is part of account opening documents and signed by the client, Relationship Manager and Business

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01399156.pdf

EFTA01399150Set 10

financial instruments. EEA Professional Client Classification Procedures — DB WM Americas https://mydb.intranet.db.com/docs/DOC-460762 All EEA clients (Account holder(s), Decision Maker(s) reside in EEA*) For all EEA clients ... discretionary DPM accounts will not be permitted. As a reminder, soliciting EEA clients is not permissible; if a client reaches out to us, we are permitted to proceed with ... revserse solicitation. The person being referred must initiate the contact Accommodation trades for all EEA clients, excluding German clients: Buys for Mutual Funds/Hedge Funds will not be permitted, only sells

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01399150.pdf

EFTA01356576Set 10

2018-06-121p195w

Reverse Solicitation Controls (Excluding German Clients) • Account Opening Review Group to ensure EEA Client Declaration form is part of account opening documents and signed by the client, Relationship Manager ... Business Manager. If EEA Client Declaration form is not complete, the request must be rejected and sent back to the Relationship Manager for completion. • Confirm that all fields are completed ... There will be no exception to open the account without signed declaration form for EEA Client. • If WM NOC receives re-opening request and client falls under EEA regulation (EEA

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356576.pdf

EFTA01356925Set 10

EEA Branch or (b) a Non-EEA Affiliate of DBAG that e) Non-EEA Client means a Client, is booked to an EEA Branch, (Non-EEA that is determined ... Branch ofDBAG in respect of Non-EEA Business that is carried on by f) EEA Client means any Client which a Non-EEA Branch or a Non-EEA ... EEA Client. Affiliate of DBAG but booked to such g) UK means the United Kingdom of EEA Branch of DBAG (and business Great Britain and Northern Ireland. may be regarded

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356925.pdf

EFTA01356958Set 10

EEA Branch or (b) a Non-EEA Affiliate of DBAG that e) Non-EEA Client means a Client, is booked to an EEA Branch, (Non-EEA that is determined ... Branch ofDBAG in respect of Non-EEA Business that is carried on by f) EEA Client means any Client which a Non-EEA Branch or a Non-EEA ... EEA Client. Affiliate of DBAG but booked to such g) UK means the United Kingdom of EEA Branch of DBAG (and business Great Britain and Northern Ireland. may be regarded

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356958.pdf

EFTA01356571Set 10

Legal and Compliance in both the US and Europe, must be obtained. 2. All EEA Clients (excluding Germany) must be serviced on a fully REVERSE SOLICITATION basis ... make ANY reccomendations to this customer. 3. All EEA Clients (excluding Germany) must sign the EEA Client Declaration form as evidence of non- solicitation. Once the client provides the signed ... products and services with a non-US client. If the client is an EEA client with a DPM and/or Deposit account, and the communication is in reference to -Additional Funds

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356571.pdf

EFTA01356568Set 10

EEA Client Identification The European Economic Area is not a target market for WM Americas, thus EEA accounts are limited (case by case) and should follow the proper approval process ... facing staff is prohibited from actively soliciting or offering any products or services to EEA clients. Since there are restrictions on activity for all EEA countries, EEA client identification ... important to ensure compliance with regulatory requirements and implemented controls. Criteria to identify EEA client or EEA account: • IndividuaUJoint accounts: o Account holder(s) resides in the EEA o Primary

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356568.pdf

EFTA01356570Set 10

required approvals are attached to the non-target lead request prior to their approval. EEA Client Declaration Form http://americas.awm.intranet.db.comien/html/56462.php 1. All EEA Clients (excluding Germany) must sign ... EEA Client Declaration form as evidence of non- solicitation. Once the client provides the signed form, their banker must also sign. 2. If the client is a pre-existing client ... Manager should only sign once ALL approvals have been obtained. 3. Once completed, the EEA client declaration form must be attached within the account opening process and routed, with

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356570.pdf

EFTA01356551Set 10

2019-04-111p344w

reduce the number of customer owners per Sub-GMTs to service existing and new EEA clients. EEA relationships/accounts must always be the result of Reverse Solicitation (client exclusively initiates ... facing staff is prohibited from actively solicit or offer any products or services to EEA clients. This SII is to track the implementation of the EEA Designated Bankers Team ... service existing and new EEA clients. Implementation will include: 1. Mgmt to identify EEA designated bankers 2. Sub-GMTs to complete relationship/account transfers 3. Implementation of control framework Due date

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356551.pdf

EFTA01356577Set 10

Custody: Confirm German clients filled out agreement supplement specific to German clients (check if EEA client field and country field, if "EEA type" does NOT contain "N/A" or blank ... Deposits, Trust, etc.): No non-GAT bankers can open German domiciled accounts (check if EEA client field and country field, if "EEA Type" does not contain "N/A" or blank ... review Banker's sub-GMT information review Alias field in DB Force. • For EEA clients where in DB force it is given as retail they cannot be allowed to open

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356577.pdf

EFTA01356575Set 10

Table: Account Opening Review Group Product Type WM NOC Deposits, Custody DPM and Trust • EEA client identified on dbforce Customer page, 'EEA Country' field. For each new account, Please check ... marked as EEA in Dbforce on customer page (EEA Client type = "Retail or "Professional") and EEA country. If EEA country is Germany, proceed with existing requirements (MIFID II Regulation

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356575.pdf

EFTA01399165Set 10

Reverse solicitation evidence for existing was obtained through: EEA Bankers attestation form (Internal form) EEA Client declaration form (External form) Each reverse solicitation form was reviewed and approved ... result, the project team drafted a proposal identifying bankers across Sub-GMTs to service EEA clients. The proposal was shared with Sub-GMT Heads and they are currently implementation details

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01399165.pdf

EFTA01399161Set 10

Changes Purpose: to locate accounts that are not properly code for EEA/to update the EEA Client Field on NetX360 and add/remove the Rules Engine coding. Useful link regarding EEA ... coded. On NetX360 under Acct Settings, update by adding "RETAIL" to the EEA Client field: Add Rule 1900 to the Rules Engine on Pershing mainframe Tool/Rule/Raup — press F4 — then ... under Acct Settings, update by deleting "RETAIL" or "RETAIL - UK HNW COMPANY" from the EEA Client field. (You may see "professional" or "per se professional" instead of "retail

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01399161.pdf

EFTA01356555Set 10

2019-04-301p360w

imposes certain requirements on a third country legal entity (non-EEA subsidiary) who services EEA clients. US WM complied with MIFID II for German clients. For remaining EEA countries excluding ... retain accormts/mnediation - Implement processcontrols to capture reverse solicitation evidence (banker's attestation or EEA client declaration form) and obtain approvals from US compliance & DLit. 4. bi-:A exit accounts Mail

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356555.pdf

EFTA01356557Set 10

Eur2in or Annualized Rev>Eur20k). hi. Obtained reverse solicitation evidence (bankers attestation or EEA Client Declaration form) and reviewed with US compliance & DCO. iv. Exited/restriced EEA accounts not meeting financials ... lead/prospect. account, and transaction levels. In Implemented and communicated process to Identify EEA clients to ABR/AFC (see attached evidence for operational effectiveness). • Implemented controls (checklist) for doimicle changes into ... impacted staff. • Drafted proposed controls for EEA designated bankers team to be implemented for EEA clients. Rationale for holistic vs localised approach (complete for F3-F4 seventy findings( Localised approach

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356557.pdf

EFTA01399167Set 10

Exception report Daily Middle Office Exception report Evidence # 2: Mismatch EEA Report Description: outlines EEA client identification mismatches between dbForce and IT logic to identify EEA clients. Worksheet

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01399167.pdf

EFTA01356558Set 10

stops are being followed by respective teams. Controls Implemented approval process for the new EEA clients'accounts. Implemented reverse solicitation controls at the leadprospect. account. and transaction levels. Implemented controls ... amended controls: I Proce.. a. derermi IR' ( USt011IVIN - Detail process toassess EEA client applicability for new clients and changes. for existing clients and update LEA type•EEA country fields

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356558.pdf

EFTA01356626Set 10

letter is required) g. In case of Custody account : 1. For German clients, when EEA client type is "Retail" then only Accommodation Sell trades are permitted via US WM moreover ... client name" on "Date" at "Time" 2. For Non-German clients, when EEA client type is "Retail" then Buy/Sell of stocks and bonds are permitted. Bill Payments Process Overview

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356626.pdf

EFTA01356619Set 10

global plus. • In case of Custody accounts : I. For German clients, whenever EEA client type is retail, only Accommodation Sell trades are permitted via US WM moreover as an interim ... Germany, DVP trade can be executed. • 2. For Non-German Client, whenever EEA client type is retail, MutuaVHedge funds- Buy is not permissible, only Sell. Free Receipt Security to Global

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356619.pdf

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Results by Dataset44 total

Set 10

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