Oral agreement with Deutsche Bank 7 we didn't want to
give UBO info to DB because of confidentiality._would
connect with local DB rep, who would send inquiries to US. We
don't name UBO, just say nationality residency. Those are only
the ones that come back with inquiries (a small number of them).
They never raised the issue oft UBO name not being disclosed
hout the duration of the relationshi no one complained
(neither DB nor Commerce Bank nor Reifeisen). First case of
actually providing UBO name was postaFinCEN. We just didn't
type the name and send it to them. We always had the U80 on
file. If there had been a problem, you would expect to hear from
your clearers, but they were happy. Arrangement wasn't
documented.