From: 

Sent: 'iS Januan/ 20141709 

To: 

Subject investigation Conclusion 7 Strictly Private and Confidential
Dear-

Furtherto the allegations you made in your e-mail oix'" Novembeno-gardins the tundun of
Accuiry in the UK, I have concluded my investigation into the matter.

This investigation has taken a few weeks, as it included:

- A lull review atyour allegations as contained in yaur spread sheet. This included cross checking the
relevant sanctions regimes applicable to the business, the dates the sanctlons were implemented and a
review or any exemptions applicable to the business,

- An interview with yourselland other relevant members distarr.
. I A wide and ln-depth analysis ofthousarids of llnes oi sales data for the Acculty UK business to ascertain
a whether there were any potential relevant sanctions breaches that you had not raised.
A review by external legal counsel to canfirm the conclusions reached by my investigation.
Review of the report by the Reed Elsevier Head of Compliance.

Following (his thorough review, the conclusiuns are set out below.
Conclu ans

1. Although historic processes and training could have been Improved and formalised, there is no evidence
of any attempt by employees to bypass the international sanctions regulations to win business

2. rha allegations are wholly related to historic transactions that had already expired or
been (erminated at the time (he allegallons were made. Ancilin did not entEr inlu new business with
any sanctioned entity.

3, There has been no breach of US sanctions regulations at any lime In the perlod of 20092013

A. Given the conclusions, there 'is no requirement on the business to report to any regulator.

 

5. There is a need to ensure that bener training is available for start on the Accuity sanctions policy to
Evuld Confusion in xhe luture New polity and processes documents have already been written and are
in the process of being rolled out,

We are grateful to you for raising your concerns. However, having looked at the allegations in detail, many 01
them arise irom a lack at understanding on your part or the pertinent racts regarding

- Wha was a client of BankersAlmanaE vs Accuity and when;

. which sanctions regimes are relevant to the BankersAlmanac vs Accuity businesses (for example, the
UK business is under no obligation to comply with 

- When Accuity inc was purchased and merged with BankevsAlmanac; and

a What reporting Reed Elsevier routinely makes to the us regulators regarding its dealings with OFAC
sanctioned countries.

 

On behalfuf RBI would like In lhankvou rm ra'wsing [Ms issue and for allowing me the urns to Investigme it
fully. is entire'y without foundation to suggestthal the busmess or its personnel have condoned :eymrism in
any way. Having conducted this thorough investigafion hope we mane! can now be closed

Regards,

kaed 
Qudfilram HOUSE, The Quailmnt, Suttun, Sunvv, 5M2 5A5:

es com