Dws Investments Australia Limited

Event Detail: DEUTSCHE BANK AG ("DBAG") -- THE INDIRECT PARENT OF DWS INVESTMENTS AUSTRALIA LIMITED (DIAL) -- ENTERED INTO A THREE-YEAR DEFERRED PROSECUTION AGREEMENT TO SETTLE WIRE FRAUD AND ANTITRUST CHARGES IN CONNECTION WITH MANIPULATIVE ACTIVITY RELATING TO US DOLLAR LIBOR AND ANTI-COMPETITIVE CONDUCT RELATING TO YEN LIBOR. DBAG ALSO AGREED TO PAY A FINE OF $625 MILLION. THE FINE WAS PAID ON 5/1/15 AND DBAG AGREED TO INSTALL A MONITOR FOR A PERIOD OF THREE YEARS (LATER EXTENDED), WHICH IS CHARGED WITH OVERSEEING THE BANK'S COMPLIANCE CONTROLS AMONGST OTHER ISSUES. Status: Final Disposition: CHARGES WERE DISMISSED ON 5/24/18. Summary: THE CHARGES RELATED TO MANIPULATIVE ACTIVITY RELATING TO US DOLLAR LIBOR BETWEEN APPROXIMATELY 2003 AND AT LEAST 2010, AND ANTI-COMPETITIVE CONDUCT RELATING TO YEN LIBOR FROM AT LEAST AS EARLY AS 2008 THROUGH AT LEAST 2010. ON MAY 23, 2018, PURSUANT TO THE TERMS OF THE DEFERRED PROSECUTION AGREEMENT, THE DEPARTMENT OF JUSTICE MOVED TO DISMISS THE WIRE FRAUD AND ANTITRUST CHARGES AGAINST DBAG; ON MAY 24, 2018 THE COURT GRANTED THE DEPARTMENT OF JUSTICE'S MOTION AND DISMISSED THE CHARGES AGAINST DBAG.

Event Detail: ON JANUARY 7, 2021, AS PART OF A DEFERRED PROSECUTION AGREEMENT ("DPA") BETWEEN DEUTSCHE BANK AG ("DBAG") AND THE U.S. DEPARTMENT OF JUSTICE ("DOJ"), A CRIMINAL INFORMATION WAS FILED CHARGING DBAG WITH (1) ONE COUNT OF FELONY CONSPIRACY TO VIOLATE THE BOOKS AND RECORDS AND INTERNAL ACCOUNTING CONTROLS PROVISIONS OF THE FOREIGN CORRUPT PRACTICES ACT ("FCPA") UNDER 18 U.S.C. §§ 371 AND 3551 ET SEQ., AND (2) ONE COUNT OF FELONY CONSPIRACY TO COMMIT WIRE FRAUD AFFECTING A FINANCIAL INSTITUTION IN RELATION TO COMMODITIES TRADING PRACTICES INVOLVING PUBLICLY TRADED PRECIOUS METALS FUTURES CONTRACTS, UNDER 18 U.S.C. §§ 1349 AND 3551 ET SEQ. DBAG ENTERED A PLEA OF NOT GULITY TO THE CHARGES AND PROSECUTION OF THE CHARGES WAS DEFERRED PURSUANT TO THE DPA. Status: Final Disposition: ON JANUARY 7, 2021, A DPA WAS FILED BETWEEN DBAG AND DOJ WHICH DEFERRED PROSECUTION OF THE CHARGES AGAINST DBAG FOR THREE YEARS. DBAG ENTERED A PLEA OF NOT GUILTY TO THE CHARGES. THE PARTIES AGREED THAT SUBJECT TO DBAG'S FULL COMPLIANCE WITH THE TERMS OF THE DPA, THREE YEARS FROM JANUARY 7, 2021, THE DPA WOULD EXPIRE, AND WITHIN SIX MONTHS AFTER THE DPA'S EXPIRATION, DOJ WOULD SEEK DISMISSAL WITH PREJUDICE OF THE CRIMINAL INFORMATION FILED AGAINST DBAG, AND AGREE NOT TO FILE CHARGES IN THE FUTURE AGAINST THE COMPANY BASED ON THE CONDUCT DESCRIBED IN THE DPA AND THE STATEMENT OF FACTS. REGARDING THE FCPA CHARGE, DBAG AGREED TO A CRIMINAL MONETARY PENALTY OF $79,561,206, WHICH WAS TIMELY PAID ON JANUARY 15, 2021, AND, AMONG OTHER THINGS, A CORPORATE COMPLIANCE REPORTING REQUIREMENT FOR THREE YEARS. REGARDING THE COMMODITIES-TRADING CHARGE, DBAG AGREED TO A CRIMINAL MONETARY PENALTY OF $5,625,000, WHICH WAS FULLY CREDITED AGAINST A CIVIL MONETARY PENALTY PAID IN CONNECTION WITH A JANUARY 29, 2018 CFTC SETTLEMENT, AS WELL AS A DISGORGEMENT OF $681,480 AND THE ESTABLISHMENT OF A VICTIM-COMPENSATION PAYMENT OF $1,223,738. THE DISGORGEMENT WAS TIMELY PAID ON JANUARY 20, 2021; ANY AMOUNT REMAINING UNCLAIMED FROM THE ESCROW ACCOUNT 12 MONTHS AFTER THE EXECUTION OF THE DPA REVERTED TO THE UNITED STATES AS AN ADDITIONAL CRIMINAL MONETARY PENALTY. FOLLOWING THE EXPIRATION OF THE THREE-YEAR TERM OF THE DPA, DOJ FILED A MOTION TO DISMISS THE CRIMINAL INFORMATION WITH PREJUDICE ON JULY 3, 2024, AND THE COURT ORDERED THE DISMISSAL OF THE CRIMINAL INFORMATION WITH PREJUDICE ON JULY 5, 2024. Summary: REGARDING THE FCPA CHARGE, THE DOJ ALLEGED THAT DBAG IMPROPERLY USED THIRD-PARTY INTERMEDIARIES TO OBTAIN AND RETAIN GLOBAL BUSINESS FROM ABOUT 2009 THROUGH AT LEAST 2016. THE DOJ ALLEGED THAT DBAG MAINTAINED FALSE BOOKS, RECORDS, AND ACCOUNTS THAT DID NOT ACCURATELY AND FAIRLY REFLECT THE TRANSACTIONS AND DISPOSITIONS OF DBAG'S ASSETS. THE DOJ ALSO ALLEGED THAT DBAG FAILED TO IMPLEMENT AND MAINTAIN SUFFICIENT INTERNAL ACCOUNTING CONTROLS TO HELP DETECT AND STOP SUCH TRANSACTIONS. REGARDING THE COMMODITIES-TRADING CHARGE, THE DOJ ALLEGED THAT, FROM ABOUT 2008 THROUGH AT LEAST 2013, FORMER DBAG EMPLOYEES CONSPIRED AND SCHEMED TO DECEIVE OTHER PRECIOUS METALS MARKET PARTICIPANTS BY CREATING AND COMMUNICATING MATERIALLY FALSE AND MISLEADING INFORMATION REGARDING SUPPLY OR DEMAND, IN ORDER TO INDUCE SUCH OTHER MARKET PARTICIPANTS INTO TRADING PRECIOUS METALS FUTURES CONTRACTS. DBAG ENTERED A PLEA OF NOT GUILTY TO THE CHARGES AND PROSECUTION OF THE CHARGES WAS DEFERRED PURSUANT TO THE DPA. FOLLOWING THE EXPIRATION OF THE THREE-YEAR TERM OF THE DPA, DOJ FILED A MOTION TO DISMISS THE CRIMINAL INFORMATION WITH PREJUDICE ON JULY 3, 2024, AND THE COURT ORDERED THE DISMISSAL OF THE CRIMINAL INFORMATION WITH PREJUDICE ON JULY 5, 2024.

Event Detail: PROVISION CONTRARY TO SECTION 44ZZRF(1) OF THE COMPETITION AND CONSUMER ACT 2010 (CTH). THE CHARGE IS A FELONY UNDER THE FORM BD/ADV DEFINITION. ON FEBRUARY 11, 2022, THE COMMONWEALTH DIRECTOR OF PUBLIC PROSECUTIONS FILED A NOLLE PROSEQUI WITH THE FEDERAL COURT OF AUSTRALIA, DECLINING TO PROCEED IN THE PROSECUTION OF DEUTSCHE BANK AG ("DB AG"). THE PRODUCT TYPE IS EQUITY SECURITIES. 1 CHARGE OF GIVING EFFECT TO A CARTEL PROVISION CONTAINED IN A CONTRACT, ARRANGEMENT OR UNDERSTANDING CONTRARY TO SECTION 44ZZRG(1) OF THE COMPETITION AND CONSUMER ACT 2010 (CTH). THE CHARGE IS A FELONY UNDER THE FORM BD/ADV DEFINITION. ON FEBRUARY 11, 2022, THE COMMONWEALTH DIRECTOR OF PUBLIC PROSECUTIONS FILED A NOLLE PROSEQUI WITH THE FEDERAL COURT OF AUSTRALIA, DECLINING TO PROCEED IN THE PROSECUTION OF DB AG. THE PRODUCT TYPE IS EQUITY SECURITIES. Status: Final Disposition: ON AUGUST 16, 2021, DEUTSCHE BANK AG ("DB AG") WAS CHARGED WITH ONE COUNT OF MAKING A CONTRACT, ARRANGEMENT OR UNDERSTANDING CONTAINING A CARTEL PROVISION CONTRARY TO SECTION 44ZZRF(1) OF THE COMPETITION AND CONSUMER ACT 2010 (CTH) AND ONE COUNT OF GIVING EFFECT TO A CARTEL PROVISION CONTAINED IN A CONTRACT, ARRANGEMENT OR UNDERSTANDING CONTRARY TO SECTION 44ZZRG(1) OF THE COMPETITION AND CONSUMER ACT 2010 (CTH). ON FEBRUARY 11, 2022, THE COMMONWEALTH DIRECTOR OF PUBLIC PROSECUTIONS FILED A NOLLE PROSEQUI WITH THE FEDERAL COURT OF AUSTRALIA, DECLINING TO PROCEED IN THE PROSECUTION OF DB AG. Summary: ON JUNE 1, 2018, DB AG WAS ISSUED A COURT ATTENDANCE NOTICE WITH RESPECT TO SIX CHARGES IN THE LOCAL COURT OF NEW SOUTH WALES, FOLLOWED BY THE ISSUANCE OF A CHARGE CERTIFICATE ON MARCH 19, 2019 AND ENTRY OF A NOT-GUILTY PLEA ON DECEMBER 8, 2020. THE MATTER WAS THEN TRANSFERRED TO THE FEDERAL COURT, WHERE AN INITIAL INDICTMENT WAS FILED ON FEBRUARY 2, 2021. ON AUGUST 16, 2021, DB AG WAS CHARGED UNDER A SUPERSEDING INDICTMENT WITH ONE COUNT OF MAKING A CONTRACT, ARRANGEMENT OR UNDERSTANDING CONTAINING A CARTEL PROVISION CONTRARY TO SECTION 44ZZRF(1) OF THE COMPETITION AND CONSUMER ACT 2010 (CTH) AND ONE COUNT OF GIVING EFFECT TO A CARTEL PROVISION CONTAINED IN A CONTRACT, ARRANGEMENT OR UNDERSTANDING CONTRARY TO SECTION 44ZZRG(1) OF THE COMPETITION AND CONSUMER ACT 2010 (CTH). IN ITS INDICTMENT, THE COMMONWEALTH DIRECTOR OF PUBLIC PROSECUTIONS ("CDPP") ALLEGED THAT ON AUGUST 8, 2015, DB AG ENTERED INTO AN ARRANGEMENT WITH TWO OTHER INVESTMENT BANKS TO RESTRICT OR LIMIT EACH OF THE BANKS' TRADING IN AUSTRALIA AND NEW ZEALAND BANKING GROUP LIMITED SHARES ("ANZ SHARES"). ON FEBRUARY 11, 2022, THE COMMONWEALTH DIRECTOR OF PUBLIC PROSECUTIONS FILED A NOLLE PROSEQUI WITH THE FEDERAL COURT OF AUSTRALIA, DECLINING TO PROCEED IN THE PROSECUTION OF DB AG.

Allegations: THE VERBRAUCHERZENTRALE BADEN-WÜRTTEMBERG E.V. ("VZBW") ALLEGED THAT DWS INVESTMENT GMBH ("DWS") MADE MISLEADING STATEMENTS IN VIOLATION OF THE GERMAN ACT AGAINST UNFAIR COMPETITION ("UWG") IN TWO MARKETING DOCUMENTS FOR A FUND ENTITLED "DWS INVEST ESG CLIMATE TECH" USED VIS-À-VIS CONSUMERS IN GERMANY. Status: Final Summary: ON JULY 27, 2022, VZBW SENT A LETTER (THE "LETTER") TO DWS DEMANDING THAT DWS CEASE AND DESIST FROM MAKING CERTAIN STATEMENTS IN TWO MARKETING DOCUMENTS FOR A FUND ENTITLED "DWS INVEST ESG CLIMATE TECH" USED VIS-À-VIS CONSUMERS IN GERMANY WHICH THE VZBW ALLEGED WERE IN VIOLATION OF THE UWG. ON AUGUST 18, 2022, DWS RESPONDED TO THE LETTER AND DENIED THE STATEMENTS IN THE MARKETING DOCUMENTS WERE IN VIOLATION OF THE UWG. ON OCTOBER 14, 2022, VZBW SERVED DWS WITH THE LAWSUIT, ALLEGING THE SAME VIOLATIONS AS IN THE LETTER, IN THE LANDGERICHT FRANKFURT AM MAIN (THE DISTRICT COURT OF FRANKFURT AM MAIN). ON MARCH 7, 2023, DWS, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AGREED WITH VZBW TO THE SETTLEMENT, IN WHICH DWS AND VZBW AGREED THAT BEGINNING MARCH 22, 2023, DWS WOULD NO LONGER USE THE TWO MARKETING DOCUMENTS FOR THE FUND DWS ESG CLIMATE TECH VIS-À-VIS CONSUMERS IN GERMANY WITHOUT MAKING CERTAIN CHANGES TO THE MARKETING DOCUMENTS AND ISSUING A CORRESPONDING DECLARATION. BOTH DWS AND VZBW SUBSEQUENTLY DECLARED THAT A COURT DECISION WAS NO LONGER NEEDED AND THE LANDGERICHT FRANKFURT AM MAIN DECLARED THE LAWSUIT TO BE OVER WITHOUT A COURT RULING ON MARCH 10, 2023 DUE TO THE SETTLEMENT.

Allegations: THE MILAN PUBLIC PROSECUTOR ALLEGED THAT DEUTSCHE BANK AG/DEUTSCHE BANK AG LONDON BRANCH ("DB AG") FAILED TO PROVIDE ADEQUATE MANAGEMENT AND SUPERVISION UNDER ITALIAN LEGISLATIVE DECREE 231 (NON-CRIMINAL LIABILITY) IN CONNECTION WITH ALLEGEDLY UNLAWFUL REPO TRANSACTIONS BETWEEN DB AG AND BANCA MONTE DEI PASCHI DI SIENA ("BMPS") AND ITS SUBSIDIARY SANTORINI. THE TRANSACTIONS WERE ALLEGEDLY INTENDED TO HIDE BMPS LOSSES BY ALLOWING BMPS TO ACCOUNT FOR THE TRADES AS A FINANCING ON AN ACCRUAL BASIS, AND PERMITTED SOME BMPS SENIOR MANAGEMENT TO DISSEMINATE FALSE INFORMATION TO THE MARKET THROUGH THE PUBLICATION OF PRESS RELEASES QUOTING FINANCIAL DATA EMERGING FROM CERTAIN BMPS FINANCIAL STATEMENTS. Status: Pending Summary: ON NOVEMBER 8, 2019, THE TRIBUNALE ORDINARIO DI MILANO - SEZIONE SECONDA FOUND DB AG LIABLE (NON-CRIMINALLY) FOR FAILING TO PROVIDE ADEQUATE MANAGEMENT AND SUPERVISION, IN CONNECTION WITH ALLEGEDLY UNLAWFUL REPO TRANSACTIONS BETWEEN DB AG AND BANCA MONTE DEI PASCHI DI SIENA ("BMPS") AND ITS SUBSIDIARY SANTORINI. THE COURT ALSO SUBJECTED DB AG TO CONFISCATION OF 64.891 MILLION EUROS IN PROFITS AND FINED DB AG 3 MILLION EUROS. THE PENALTIES AND SENTENCES WILL ONLY BECOME EFFECTIVE AFTER THE CONCLUSION OF ANY APPEAL.

Allegations: THE CFTC ALLEGED THAT, WITH RESPECT TO THE REPORTING OF SWAP DATA, DEUTSCHE BANK AG ("DBAG") FAILED TO PROPERLY REPORT AND CORRECT ERRORS IN REAL-TIME DATA, TO CORRECT ERRORS AND OMISSIONS IN PREVIOUSLY REPORTED DATA, PROVIDE DILIGENT SUPERVISION, AND MAINTAIN AN ADEQUATE BUSINESS CONTINUITY AND DISASTER RECOVERY PLAN. THE CFTC ALSO ALLEGED THAT DBAG VIOLATED A 2015 CFTC ORDER THAT RESOLVED A CFTC INVESTIGATION INTO A DIFFERENT TYPE OF SWAP REPORTING ERROR. Status: Final Summary: IN AUGUST 2016, THE CFTC FILED A COMPLAINT IN THE U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ("SDNY") FOLLOWING AN INADVERTENT FIVE-DAY OUTAGE OF DBAG'S SWAP REPORTING PLATFORM IN APRIL 2016. DURING THE OUTAGE, DBAG WAS UNABLE TO SUBMIT ANY PRICE OR TRANSACTION DATA TO THE DATA REPOSITORY. AT THE TIME OF THE OUTAGE, DBAG WAS SUBJECT TO A CFTC SETTLEMENT ORDER DATED SEPTEMBER 30, 2015, ARISING OUT OF A DIFFERENT TYPE OF SWAP REPORTING ERROR, WHICH REQUIRED DBAG TO REMEDIATE ITS SWAP DATA REPORTING PROGRAM. IN CONNECTION WITH THESE REMEDIAL UNDERTAKINGS, DBAG ATTEMPTED TO PERFORM A MAINTENANCE UPGRADE TO ITS SWAP REPORTING PLATFORM, DURING WHICH ITS VENDOR CAUSED THE OUTAGE BY INADVERTENTLY COPYING OUTDATED OR UNSYNCHRONIZED DATA FILES FROM THE BACKUP PLATFORM TO THE MAIN PLATFORM. BECAUSE THE BACKUP PLATFORM WAS ALSO AFFECTED, DBAG WAS UNABLE TO PROMPTLY RESUME REPORTING AFTER THE INCIDENT AS PRESCRIBED BY ITS BUSINESS CONTINUITY AND DISASTER RECOVERY PLAN. DBAG PROMPTLY NOTIFIED THE CFTC OF THE OUTAGE AND PROVIDED EXTENSIVE COOPERATION TO THE CFTC'S STAFF FROM THE TIME OF THE OUTAGE THROUGH THE TIME OF THE RESOLUTION OF THE LAWSUIT. ON JUNE 17, 2020, DBAG, WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS THEREIN, ENTERED INTO A SETTLEMENT WITH THE CFTC. SDNY APPROVED THE SETTLEMENT IN ITS CONSENT ORDER FOR PERMANENT INJUNCTION, CIVIL MONETARY PENALTY, AND OTHER EQUITABLE RELIEF AGAINST DEUTSCHE BANK AG (THE "ORDER"). THE ORDER ENJOINED DBAG FROM VIOLATING CERTAIN CEA PROVISIONS AND CFTC RULES RELATED TO SWAP DATA REPORTING REQUIREMENTS, BUSINESS CONTINUITY AND DISASTER RECOVERY PLANNING, AND SUPERVISION; ORDERED DBAG TO COMPLY WITH ITS 2015 CFTC ORDER; AND REQUIRED DBAG TO PAY A CIVIL MONEY PENALTY OF $9,000,000, THE FINE WAS PAID ON JULY 1, 2020.

Allegations: IFUS ALLEGES THAT DEUTSCHE BANK AG MAY HAVE VIOLATED EXCHANGE RULE 4.06(B) (V) BY NOT MAINTAINING CONFIRMATION STATEMENTS TO SUBSTANTIATE THE RELATED PHYSICAL TRADE IN CURRENCY EXCHANGE FOR PHYSICAL TRANSACTIONS IN NUMEROUS INSTANCES BETWEEN SEPTEMBER 2011 AND DECEMBER 2013. Status: Final Sanction Detail: DBAG WAS ORDERED TO PAY A FINE OF $ 650,000.00 THE FINE WAS PAID ON MARCH 12, 2015. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBAG AGREED TO PAY THE FINE OF $650,000.00 WHICH WAS PAID ON MARCH 12, 2015. DBAG AGREED TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF IFUS RULE 4.06(B) (V).

Allegations: ICE FUTURES U.S., INC. ALLEGED DBAG VIOLATED EXCHANGE RULE 6.20(B) IN ONE INSTANCE BY EXCEEDING THE SPOT MONTH SPECULATIVE POSITION LIMIT ESTABLISHED BY THE EXCHANGE FOR THE HENRY HUB LD1 FIXED PRICE FUTURES CONTRACT DURING THE 2014 EXPIRATION. Status: Final Sanction Detail: THE AMOUNT OF $194,580.00 REPRESENTS A $20,000.00 (FINE PORTION) AND $174,580.00 REPRESENTS DIGORGEMENT OF PROFITS. THERE WAS ALSO AN AGREEMENT TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF EXCHANGE RULE 6.20(B). Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBAG AGREED TO THE SETTLEMENT AND TO PAY THE FINE AND DISGORGEMENT.

Allegations: CME GROUP ALLEGED DEUTSCHE BANK AG ("DBAG") VIOLATED LEGACY CBOT RULES 534 (WASH TRADES PROHIBITED), 538.A (NATURE OF AN EFRP) AND 538.B (RELATED POSITIONS). THESE TRANSACTIONS OCCURRED ON JUNE 4, 2013 AND AUGUST 29, 2013. Status: Final Sanction Detail: DBAG AGREED TO PAY THE $60,000.00 FINE. IT WAS PAID ON MARCH 16, 2016. Summary: WITHOUT ADMITTING OR DENYING ANY RULE VIOLATIONS, DBAG AGREED TO PAY THE FINE OF $60,000.00 WHICH WAS PAID ON MARCH 16, 2016.

Allegations: ON JULY 24, 2014, A CHICAGO BOARD OF TRADE BUSINESS CONDUCT COMMITTEE ACCEPTED A $60,000.00 FINE FROM DEUTSCHE BANK AG (DBAG) IN CONNECTION WITH ALLEGATIONS THAT DBAG VIOLATED CBOT RULE 562 (POSITION LIMIT VIOLATION). SPECIFICALLY, IT WAS ALLEGED THAT ON DECEMBER 12, 2013, DBAG HELD INTRADAY LONG POSITION OF 8,402 MARCH 2014 SOYBEAN OIL FUTURES CONTRACTS, WHICH EXCEEDED THE SINGLE MONTH SPECULATIVE POSITION LIMIT OF 8,000 CONTRACTS BY 42 CONTRACTS, OR BY .53%. PRIOR TO THE CLOSE ON 12/12/13, DBAG SOLD 10 CONTRACTS TO BRING ITSELF INTO COMPLIANCE WITH THE APPLICABLE LIMIT. DBAG NEITHER ADMITTED NOR DENIED THE RULE VIOLATIONS UPON WHICH THE FINE IS BASED. Status: Final Sanction Detail: DBAG WAS ORDERED TO PAY A FINE OF $60,000.00. THE FINE WAS PAID ON AUGUST 5, 2014. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBAG AGREED TO PAY THE FINE OF $60,000.00 WHICH WAS PAID ON AUGUST 5, 2014.

Allegations: CME GROUP ALLEGED THAT DBAG LONDON BRANCH EXECUTED AN EXCHANGE FOR RELATED POSITION ("EFRP") TRANSACTION ON JUNE 30, 2015 IN WHICH THE RELATED POSITION TRANSACTION WAS ESTABLISHED AND OFFSET WITHOUT THE INCURRENCE OF MARKET RISK. THE TRANSACTION WAS TRANSITORY IN NATURE AND THEREFORE NON-BONA FIDE. AS A RESULT, CME ALLEGED THAT DBAG VIOLATED EXCHANGE RULE 538.C. Status: Final Sanction Detail: DBAG LONDON BRANCH AGREED TO PAY THE $15,000.00. THE FINE WAS PAID ON JUNE 6, 2016. Summary: WITHOUT ADMITTING OR DENYING ANY RULE VIOLATIONS, DBAG LONDON BRANCH AGREED TO PAY THE FINE OF $15,000.00 WHICH WAS PAID ON JUNE 6, 2016.

Allegations: CME MARKET REGULATION DEPARTMENT ALLEGED, AND CME BUSINESS CONDUCT COMMITTEE FOUND, THAT DEUTSCHE BANK AG VIOLATED CME RULES 538.C, 534 AND 432.W BY EXECUTING AN EXCHANGE OF FUTURES FOR RELATED POSITION ("EFRP") WITHOUT THE EXCHANGE OR RELATED POSITIONS, THEREBY EXECUTING A NON BONA-FIDE ERFP. Status: Final Sanction Detail: DEUTSCHE BANK AG WAS FINED $75,000 AND PAID THE FINE IN FULL ON NOVEMBER 6, 2018. Summary: THE ACTION WAS RESOLVED BY DECISION OF CME BUSINESS CONDUCT COMMITTEE DATED OCTOBER 24, 2018, WHICH BECAME EFFECTIVE ON OCTOBER 26, 2018. THE DECISION ACCEPTED AN OFFER OF SETTLEMENT FROM DEUTSCHE BANK AG AND DIRECTED DEUTSCHE BANK AG TO PAY A FINE OF $75,000 ON OR BEFORE NOVEMBER 9, 2018. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DEUTSCHE BANK AG PAID THE FINE IN FULL ON NOVEMBER 6, 2018.

Allegations: ICE FUTURES U.S., INC. ("IFUS") ALLEGED THAT DEUTSCHE BANK AG ("DB AG") MAY HAVE VIOLATED IFUS RULE 4.02(C) ON FEBRUARY 28, 2020 BY EXECUTING A BLOCK TRADE BETWEEN TWO ACCOUNTS THAT SHARED THE SAME BENEFICIAL OWNER FOR THE PURPOSE OF MOVING A POSITION FROM ONE CLEARING MEMBER TO ANOTHER. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DB AG AGREED TO A FINE OF USD $7,500, WHICH WAS TIMELY PAID ON SEPTEMBER 14, 2021. Summary: ON AUGUST 31, 2021, DB AG, WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED THEREIN, ENTERED INTO A SETTLEMENT AGREEMENT WITH IFUS. IN THE SETTLEMENT AGREEMENT, IFUS ALLEGED THAT DB AG MAY HAVE VIOLATED IFUS RULE 4.02(C) ON FEBRUARY 28, 2020 BY EXECUTING A BLOCK TRADE BETWEEN TWO ACCOUNTS THAT SHARED THE SAME BENEFICIAL OWNER FOR THE PURPOSE OF MOVING A POSITION FROM ONE CLEARING MEMBER TO ANOTHER. PURSUANT TO THE SETTLEMENT AGREEMENT, DB AG AGREED TO A FINE OF USD $7,500, WHICH WAS TIMELY PAID ON SEPTEMBER 14, 2021.

Allegations: THE CME GROUP ALLEGED THAT DEUTSCHE BANK AG'S ("DB AG") ELECTRONIC AUDIT TRAIL RELATING TO ELECTRONIC ORDER ROUTING FOR FRONT-END SYSTEMS FAILED TO MEET A CME GROUP REQUIREMENT TO MAINTAIN A COMPLETE ELECTRONIC AUDIT TRAIL FOR A MINIMUM OF FIVE YEARS. THE CME GROUP ACKNOWLEDGED THAT DB AG SUBSEQUENTLY APPLIED NEW MEASURES TO ITS RECORDKEEPING PROCESSES TO ENSURE COMPLIANCE WITH THE RELEVANT REQUIREMENT. Status: Final Sanction Detail: DBAG AGREED TO A FINE OF USD $1,000, THE FINE WILL BE PAID. Summary: ON JUNE 18, 2021, DB AG AGREED TO THE ENTRY OF A SUMMARY FINE NOTICE BY THE CME GROUP. IN THE SUMMARY FINE NOTICE, THE CME GROUP ALLEGED THAT DB AG'S ELECTRONIC AUDIT TRAIL RELATING TO ELECTRONIC ORDER ROUTING FOR FRONT-END SYSTEMS FAILED TO MEET A CME GROUP REQUIREMENT TO MAINTAIN A COMPLETE ELECTRONIC AUDIT TRAIL FOR A MINIMUM OF FIVE YEARS. THE CME GROUP ACKNOWLEDGED THAT DB AG SUBSEQUENTLY APPLIED NEW MEASURES TO ITS RECORDKEEPING PROCESSES TO ENSURE COMPLIANCE WITH THE RELEVANT REQUIREMENT. PURSUANT TO THE SUMMARY FINE NOTICE, DB AG AGREED TO A FINE OF USD $1,000, THE FINE WILL BE PAID.

Allegations: BLOOMBERG SEF LLC ("BSEF") ALLEGED THAT DEUTSCHE BANK AG ("DBAG") EXECUTED OFFSETTING AND CORRECTING TRADES FOR A JANUARY 21, 2021 TRADE AFTER THE PERMITTED TIMEFRAME OF THREE BUSINESS DAYS AND FAILED TO USE APPROPRIATE OFFSETTING TERMS AS REQUIRED UNDER BSEF RULES. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBAG AGREED TO A FINE OF USD $7,500, WHICH WAS TIMELY PAID ON 7/15/2021. Summary: ON JUNE 25, 2021, DB AG, WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED THEREIN, ENTERED INTO A WRITTEN DECISION WITH BSEF. IN THE WRITTEN DECISION, BSEF ALLEGED THAT DB AG EXECUTED OFFSETTING AND CORRECTING TRADES FOR A JANUARY 21, 2021 TRADE AFTER THE PERMITTED TIMEFRAME OF THREE BUSINESS DAYS AND FAILED TO USE APPROPRIATE OFFSETTING TERMS AS REQUIRED UNDER BSEF RULES. PURSUANT TO THE WRITTEN DECISION, DB AG AGREED TO A FINE OF USD $7,500, WHICH WAS TIMELY PAID ON 7/15/2021.

Allegations: CME GROUP EXCHANGE ("CME") ALLEGED THAT DEUTSCHE BANK AG ("DBAG") FAILED TO REPORT CERTAIN EXCHANGE FOR RELATED POSITION ("EFRP") TRADES IN A TIMELY MANNER IN ACCORDANCE WITH CME RULE 538.I. Status: Final Sanction Detail: DBAG AGREED TO A FINE OF $2,000, WHICH WILL BE TIMELY PAID. Summary: ON MAY 19, 2022, DBAG RECEIVED A PRELIMINARY DECISION FROM CME, WHICH ALLEGED THAT DBAG FAILED TO REPORT CERTAIN EFRP TRADES IN A TIMELY MANNER IN ACCORDANCE WITH CME RULES. DBAG DID NOT ADMIT OR DENY THE FINDINGS IN THE PRELIMINARY DECISION, WHICH BECAME FINAL ON JUNE 3, 2022, AND IMPOSED A FINE OF $2,000, WHICH WILL BE TIMELY PAID.

Allegations: BLOOMBERG SEF LLC (BSEF") FOUND THAT DEUTSCHE BANK AG ("DBAG") FAILED TO REPORT ERROR TRADES IN A TIMELY MANNER IN ACCORDANCE WITH BSEF RULES, AND THAT DBAG FAILED TO ADMINISTER SUPERVISORY PROCEDURES TO ENSURE THAT ERROR TRADES WERE PROPERLY REPORTED AND CORRECTED ON BSEF DESPITE NUMEROUS PREVIOUS VIOLATIONS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, DBAG AGREED TO A FINE OF USD $75,000, WHICH WAS TIMELY PAID ON MARCH 14, 2023 Summary: ON FEBRUARY 27, 2023, DBAG, WITHOUT ADMITTI NG OR DENYING THE FINDINGS CONTAINED THEREIN, ENTERED INTO A SETTLEMENT WITH BSEF, IN WHICH BSEF FOUND THAT DBAG FAILED TO REPORT ERROR TRADES IN A TIMELY MANNER IN ACCORDANCE WITH BSEF RULES, AND THAT DBAG FAILED TO ADMINISTER SUPERVISORY PROCEDURES TO ENSURE THAT ERROR TRADES WERE PROPERLY REPORTED AND CORRECTED ON BSEF DESPITE NUMEROUS PREVIOUS VIOLATIONS. DBAG AGREED TO A FINE OF USD $75,000, WHICH WAS TIMELY PAID ON MARCH 14, 2023.

Allegations: BLOOMBERG SEF LLC ("BSEF") FOUND THAT DEUTSCHE BANK AG ("DBAG") FAILED TO REPORT ERROR TRADES IN A TIMELY MANNER IN ACCORDANCE WITH BSEF RULES, AND THAT DBAG FAILED TO ADMINISTER SUPERVISORY PROCEDURES TO ENSURE THAT ERROR TRADES WERE PROPERLY REPORTED AND CORRECTED ON BSEF DESPITE NUMEROUS PREVIOUS VIOLATIONS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, DBAG AGREED TO A FINE OF USD 175,000, WHICH WAS TIMELY PAID ON JUNE 7, 2023. Summary: ON MAY 22, 2023, DBAG, WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED THEREIN, ENTERED INTO A SETTLEMENT WITH BSEF, IN WHICH BSEF FOUND THAT DBAG FAILED TO REPORT ERROR TRADES IN A TIMELY MANNER IN ACCORDANCE WITH BSEF RULES, AND THAT DBAG FAILED TO ADMINISTER SUPERVISORY PROCEDURES TO ENSURE THAT ERROR TRADES WERE PROPERLY REPORTED AND CORRECTED ON BSEF DESPITE NUMEROUS PREVIOUS VIOLATIONS. DBAG AGREED TO A FINE OF USD 175,000, WHICH WAS TIMELY PAID ON JUNE 7, 2023.

Allegations: CME GROUP ("CME") FOUND THAT DEUTSCHE BANK AG LONDON BRANCH ("DBAG LONDON"), IN VIOLATION OF CME RULE 534, OPERATED AN AUTOMATED TRADING SYSTEM THAT ENTERED MULTIPLE OPPOSING BUY AND SELL ORDERS FOR THE SAME ACCOUNT IN JUNE 2022 NEW ZEALAND DOLLARS FUTURES NONINVERTED CME FX LINK SPREADS, SWISS FRANC FUTURES INVERTED CME FX LINK SPREADS, AND EURO FX FUTURES NON-INVERTED CME FX LINK SPREADS. THESE ORDERS THEN TRADED OPPOSITE EACH OTHER IN THE SAME DBAG LONDON ACCOUNT CAUSING SELF-MATCHING TO OCCUR ON MORE THAN AN INCIDENTAL BASIS. CME ALSO FOUND THAT DBAG LONDON REASONABLY SHOULD HAVE KNOWN THAT ENTERING ORDERS IN THE MANNER IT DID WOULD ACHIEVE A WASH RESULT. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE RULE VIOLATION OR FACTUAL FINDINGS, DBAG LONDON AGREED TO A FINE OF $70,000, WHICH WILL BE TIMELY PAID. Summary: ON DECEMBER 11, 2023, DBAG LONDON ENTERED INTO A SETTLEMENT WITH CME, IN WHICH CME FOUND THAT DBAG LONDON, IN VIOLATION OF CME RULE 534, OPERATED AN AUTOMATED TRADING SYSTEM THAT ENTERED MULTIPLE OPPOSING BUY AND SELL ORDERS FOR THE SAME ACCOUNT IN JUNE 2022 NEW ZEALAND DOLLARS FUTURES NONINVERTED CME FX LINK SPREADS, SWISS FRANC FUTURES INVERTED CME FX LINK SPREADS, AND EURO FX FUTURES NON-INVERTED CME FX LINK SPREADS. THESE ORDERS THEN TRADED OPPOSITE EACH OTHER IN THE SAME DBAG LONDON ACCOUNT CAUSING SELF-MATCHING TO OCCUR ON MORE THAN AN INCIDENTAL BASIS. CME ALSO FOUND THAT DBAG LONDON REASONABLY SHOULD HAVE KNOWN THAT ENTERING ORDERS IN THE MANNER IT DID WOULD ACHIEVE A WASH RESULT. DBAG LONDON DID NOT ADMIT OR DENY THE RULE VIOLATION OR FACTUAL FINDINGS IN THE SETTLEMENT, AND AGREED TO A FINE OF $70,000, WHICH WILL BE TIMELY PAID.

Allegations: ICE FUTURES U.S., INC. ("IFUS") FOUND THAT DEUTSCHE BANK AG ("DBAG") FAILED TO COMPLY WITH IFUS RULE 4.19(C)(I) RELATING TO AUDIT TRAIL REQUIREMENTS BY NOT POPULATING A "MANUAL ORDER" IDENTIFIER ON CERTAIN ORDER MESSAGES BETWEEN JANUARY AND AUGUST 2023. Status: Final Sanction Detail: THE SUMMARY FINE NOTICE IMPOSED A FINE OF USD $10,000, WHICH WAS TIMELY PAID ON APRIL 26, 2024. Summary: ON APRIL 4, 2024, IFUS. ISSUED A SUMMARY FINE NOTICE TO DBAG, FINDING THAT DBAG FAILED TO COMPLY WITH IFUS RULE 4.19(C)(I) RELATING TO AUDIT TRAIL REQUIREMENTS BY NOT POPULATING A "MANUAL ORDER" IDENTIFIER ON CERTAIN ORDER MESSAGES BETWEEN JANUARY AND AUGUST 2023. THE SUMMARY FINE NOTICE IMPOSED A FINE OF USD $10,000, WHICH WAS TIMELY PAID ON APRIL 26, 2024.

Allegations: THE EUROPEAN COMMISSION ("COMMISSION") FOUND THAT DEUTSCHE BANK AG, DB GROUP SERVICES (UK) LIMITED, AND DEUTSCHE SECURITIES INC. (TOGETHER, "DB") AND THREE OTHER BANKS TOOK PART IN ANTICOMPETITIVE CONDUCT RELATING TO THE SECONDARY TRADING MARKET WITHIN THE EUROPEAN ECONOMIC AREA OF SUPRA-SOVEREIGN, SOVEREIGN AND AGENCY ("SSA") BONDS DENOMINATED IN U.S. DOLLARS. IN PARTICULAR, THE COMMISSION FOUND THAT FROM 2010 TO 2014, CERTAIN DB TRADERS PARTICIPATED IN A CARTEL WITH TRADERS AT THE THREE OTHER BANKS BY COORDINATING ON PRICES OF SSA BONDS QUOTED TO CLIENTS AND THE MARKET IN GENERAL, IN VIOLATION OF EUROPEAN UNION RULES PROHIBITING ANTICOMPETITIVE BUSINESS PRACTICES. AS A RESULT OF ITS VOLUNTARY DISCLOSURE AND COOPERATION WITH THE COMMISSION AND PURSUANT TO THE COMMISSION'S 2006 LENIENCY NOTICE, DB WAS GRANTED FULL IMMUNITY RELATING TO THE INFRINGEMENTS DESCRIBED IN THE DECISION. Status: Final Sanction Detail: AS A RESULT OF ITS VOLUNTARY DISCLOSURE AND COOPERATION WITH THE COMMISSION AND PURSUANT TO THE COMMISSION'S 2006 LENIENCY NOTICE, DB WAS GRANTED FULL IMMUNITY RELATING TO THE INFRINGEMENTS DESCRIBED IN THE DECISION AND AGREED TO CEASE AND DESIST FROM THE RELEVANT INFRINGEMENTS. Summary: ON APRIL 28, 2021, THE COMMISSION ISSUED A DECISION FINDING THAT DB AND THREE OTHER BANKS TOOK PART IN ANTICOMPETITIVE CONDUCT RELATING TO THE SECONDARY TRADING MARKET WITHIN THE EUROPEAN ECONOMIC AREA OF SSA BONDS DENOMINATED IN U.S. DOLLARS. IN PARTICULAR, THE COMMISSION FOUND THAT FROM 2010 TO 2014, CERTAIN DB TRADERS PARTICIPATED IN A CARTEL WITH TRADERS AT THE THREE OTHER BANKS BY COORDINATING ON PRICES OF SSA BONDS QUOTED TO CLIENTS AND THE MARKET IN GENERAL, IN VIOLATION OF EUROPEAN UNION RULES PROHIBITING ANTICOMPETITIVE BUSINESS PRACTICES. AS A RESULT OF ITS VOLUNTARY DISCLOSURE AND COOPERATION WITH THE COMMISSION AND PURSUANT TO THE COMMISSION'S 2006 LENIENCY NOTICE, DB WAS GRANTED FULL IMMUNITY RELATING TO THE INFRINGEMENTS DESCRIBED IN THE DECISION AND AGREED TO CEASE AND DESIST FROM THE RELEVANT INFRINGEMENTS.

Allegations: THE PHILIPPINES ANTI-MONEY LAUNDERING COUNCIL ("AMLC") ALLEGED THAT DEUTSCHE BANK AG ("DB AG"), MANILA BRANCH FAILED TO REPORT ALL COVERED TRANSACTIONS TO THE AMLC WITHIN FIVE WORKING DAYS, AS REQUIRED UNDER THE PHILIPPINES ANTI-MONEY LAUNDERING ACT OF 2001, AS AMENDED. IN PARTICULAR, THE AMLC ALLEGED THAT 2,069 COVERED TRANSACTION REPORTS WERE FILED BEYOND THE FIVE-DAY PERIOD DURING THE FIRST SEMESTER OF 2017. THE AMLC FOUND THAT DB AG SHOWED "GOOD CAUSE" IN ADEQUATELY REMEDIATING AML SYSTEM ISSUES, INCLUDING THE COVERED TRANSACTION REPORTS AT ISSUE. ACCORDINGLY, THE AMLC AGREED TO WITHDRAW THE CASE UPON RECEIPT OF AN ASSESSMENT PAYMENT AND CONFIRMATION OF DB AG'S REMEDIAL MEASURES. Status: Final Sanction Detail: THE AMLC IMPOSED AN ASSESSMENT OF ONE MILLION PHILIPPINE PESOS, WHICH IS APPROXIMATELY USD $21,000, WHICH WAS TIMELY PAID ON MAY 24, 2021. Summary: ON MAY 18, 2021, THE AMLC APPROVED A RESOLUTION (THE "RESOLUTION") IN CONNECTION WITH DB AG, MANILA BRANCH'S ALLEGED FAILURE TO REPORT ALL COVERED TRANSACTIONS TO THE AMLC WITHIN FIVE WORKING DAYS, AS REQUIRED UNDER THE PHILIPPINES ANTI-MONEY LAUNDERING ACT OF 2001, AS AMENDED. IN PARTICULAR, THE AMLC ALLEGED THAT 2,069 COVERED TRANSACTION REPORTS WERE FILED BEYOND THE FIVE-DAY PERIOD DURING THE FIRST SEMESTER OF 2017. THE AMLC FOUND THAT DB AG SHOWED "GOOD CAUSE" IN ADEQUATELY REMEDIATING AML SYSTEM ISSUES, INCLUDING THE COVERED TRANSACTION REPORTS AT ISSUE. ACCORDINGLY, THE AMLC AGREED TO WITHDRAW THE CASE UPON RECEIPT OF AN ASSESSMENT PAYMENT AND CONFIRMATION OF DB AG'S REMEDIAL MEASURES. THE AMLC IMPOSED AN ASSESSMENT OF ONE MILLION PHILIPPINE PESOS, WHICH IS APPROXIMATELY USD $21,000, WHICH WAS TIMELY PAID ON MAY 24, 2021.

Allegations: THE GERMAN FEDERAL FINANCIAL SUPERVISORY AUTHORITY ("BAFIN") DETERMINED THAT THE CONSOLIDATED FINANCIAL STATEMENTS OF DEUTSCHE BANK AG ("DBAG") FOR FY2019 MISAPPLIED THE INTERNATIONAL FINANCIAL REPORTING STANDARDS ("IFRS") - INTERNATIONAL ACCOUNTING STANDARDS ("IAS") RELATING TO SPECIFICS OF THE DISCLOSURE OF DEFERRED TAX ASSETS. Status: Final Sanction Detail: THE DECISION DID NOT IMPOSE A FINE OR SANCTION AGAINST DBAG. Summary: ON JULY 4, 2024, DBAG RECEIVED A DECISION FROM BAFIN DATED JUNE 28, 2024, DETERMINING THAT THE CONSOLIDATED FINANCIAL STATEMENTS OF DBAG FOR FY2019 MISAPPLIED THE IFRS - IAS RELATING TO SPECIFICS OF THE DISCLOSURE OF DEFERRED TAX ASSETS. THE DECISION DID NOT IMPOSE A FINE OR SANCTION AGAINST DBAG.

Allegations: THE EUROPEAN COMMISSION ("COMMISSION") FOUND THAT DEUTSCHE BANK AG ("DBAG") AND ANOTHER EUROPEAN BANK TOOK PART IN ANTICOMPETITIVE CONDUCT RELATING TO THE SECONDARY TRADING MARKET WITHIN THE EUROPEAN ECONOMIC AREA OF EURO-DENOMINATED SUPRA-SOVEREIGN, SOVEREIGN AND AGENCY ("SSA") AND GOVERNMENT GUARANTEED BONDS. IN PARTICULAR, THE COMMISSION FOUND THAT FROM 2006 TO 2016, CERTAIN DBAG TRADERS PARTICIPATED IN COLLUSIVE CONDUCT WITH TRADERS AT THE OTHER BANK BY COORDINATING ON PRICES OF THE RELEVANT BONDS QUOTED TO CLIENTS, IN VIOLATION OF EUROPEAN UNION RULES PROHIBITING ANTICOMPETITIVE BUSINESS PRACTICES. AS A RESULT OF ITS PROACTIVE COOPERATION WITH THE COMMISSION AND PURSUANT TO THE COMMISSION'S 2006 LENIENCY NOTICE, DBAG WAS GRANTED FULL IMMUNITY RELATING TO THE INFRINGEMENTS DESCRIBED IN THE DECISION. Status: Final Sanction Detail: AS A RESULT OF ITS PROACTIVE COOPERATION WITH THE COMMISSION AND PURSUANT TO THE COMMISSION'S 2006 LENIENCY NOTICE, DBAG WAS GRANTED FULL IMMUNITY RELATING TO THE INFRINGEMENTS DESCRIBED IN THE DECISION. Summary: ON NOVEMBER 22, 2023, THE COMMISSION ISSUED A DECISION FINDING THAT DBAG AND ANOTHER EUROPEAN BANK TOOK PART IN ANTICOMPETITIVE CONDUCT RELATING TO THE SECONDARY TRADING MARKET WITHIN THE EUROPEAN ECONOMIC AREA OF EURO-DENOMINATED SSA AND GOVERNMENT GUARANTEED BONDS. IN PARTICULAR, THE COMMISSION FOUND THAT FROM 2006 TO 2016, CERTAIN DB AG TRADERS PARTICIPATED IN COLLUSIVE CONDUCT WITH TRADERS AT THE OTHER BANK BY COORDINATING ON PRICES OF THE RELEVANT BONDS QUOTED TO CLIENTS, IN VIOLATION OF EUROPEAN UNION RULES PROHIBITING ANTICOMPETITIVE BUSINESS PRACTICES. AS A RESULT OF ITS PROACTIVE COOPERATION WITH THE COMMISSION AND PURSUANT TO THE COMMISSION'S 2006 LENIENCY NOTICE, DBAG WAS GRANTED FULL IMMUNITY RELATING TO THE INFRINGEMENTS DESCRIBED IN THE DECISION.

Allegations: THE STATEMENT OF DISCIPLINARY ACTION FOLLOWS AN SFC INVESTIGATION INTO THE FAILURE OF DBAG TO DISCLOSE TO THE STOCK EXCHANGE OF HONG KONG ("SEHK") THE CHANGES TO ITS PERCENTAGE HOLDINGS IN THE ISSUED SHARE CAPITAL OF UP ENERGY DEVELOPMENT GROUP ON OCCASIONS IN 2011 (AS REQUIRED BY SECTIONS 310(1), 311, 313(1), 315, 324 AND 325(1)(A) OF THE SECURITIES AND FUTURES ORDINANCE (CAP 571)). THREE OF THESE OCCASIONS INVOLVED TRADING ACTIVITY BY DBAG; THE REMAINDER INVOLVED INCREASES TO THE LISTED COMPANY'S TOTAL ISSUED SHARE CAPITAL. THE SFC FOUND THAT DBAG FAILED TO IMPLEMENT ADEQUATE INTERNAL CONTROLS TO ENSURE ITS POSITIONS IN HONG KONG LISTED COMPANIES WERE PROPERLY MONITORED AND DISCLOSED TO SEHK IN COMPLIANCE WITH THE DISCLOSURE OF INTEREST REQUIREMENTS. Status: Final Sanction Detail: PUBLIC REPRIMAND Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBAG PAID A FINE OF HK$1.6 MILLION. THE FINE WAS PAID ON OR ABOUT 22 MAY 2014.

Allegations: THE STATE BANK OF PAKISTAN ("SBP") FOUND THAT DEUTSCHE BANK AG ("DBAG"), THROUGH ITS KARACHI BRANCH, REPATRIATED DIVIDENDS TO A FOREIGN COMPANY FROM 2012 TO 2019 WITHOUT AUTHORIZATION FROM THE SBP IN VIOLATION OF PARA 16(I), CHAPTER 14 OF THE PAKISTAN FOREIGN EXCHANGE MANUAL UNDER THE FOREIGN EXCHANGE REGULATION ACT. Status: Final Sanction Detail: N/A Summary: IN A WARNING LETTER DATED JULY 21, 2022, THE SBP FOUND THAT DBAG, THROUGH ITS KARACHI BRANCH, REPATRIATED DIVIDENDS TO A FOREIGN COMPANY FROM 2012 TO 2019 WITHOUT AUTHORIZATION FROM THE SBP IN VIOLATION OF PARA 16(I), CHAPTER 14 OF THE PAKISTAN FOREIGN EXCHANGE MANUAL UNDER THE FOREIGN EXCHANGE REGULATION ACT, BUT DID NOT IMPOSE ANY MONETARY PENALTY, RESTRICTIONS OR LIMITATIONS ON DB AG'S BUSINESS OR UNDERTAKINGS, OR ANY OTHER SANCTIONS.

Allegations: EUREX DEUTSCHLAND ("EUREX") FOUND THAT, FROM APRIL 2021 THROUGH JUNE 2021, DEUTSCHE BANK AG, FRANKFURT AM MAIN ("DB AG") FAILED TO CONVERT 126 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 72 OF THE EUREX EXCHANGE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. Status: Final Sanction Detail: EUREX ISSUED A REPRIMAND TO DB AG Summary: ON FEBRUARY 10, 2022, DB AG RECEIVED A DECISION FROM EUREX FINDING THAT, FROM APRIL 2021 THROUGH JUNE 2021, DB AG FAILED TO CONVERT 126 SHORT CODES INTO LONG CODES AS REQUIRED BYSECTION 72 OF THE EUREX EXCHANGE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014, AND ISSUINGA REPRIMAND TO DB AG. THE DECISION BECAME FINAL ON MARCH 10, 2022.

Allegations: THE FRANKFURT STOCK EXCHANGE ("FSE") FOUND THAT, FROM JUNE 2021 THROUGH OCTOBER 2021, DEUTSCHE BANK AG, FRANKFURT AM MAIN ("DB AG") FAILED TO CONVERT 366 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. Status: Final Sanction Detail: FSE ISSUED A REPRIMAND TO DB AG, BUT DID NOT IMPOSE A FINE OR OTHER MONETARY SANCTION. Summary: ON APRIL 25, 2022, DB AG RECEIVED A DECISION FROM FSE FINDING THAT, FROM JUNE 2021 THROUGH OCTOBER 2021, DB AG FAILED TO CONVERT 366 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014, AND ISSUING A REPRIMAND TO DB AG, BUT NOT IMPOSING A FINE OR OTHER MONETARY SANCTION. THE DECISION BECAME FINAL ON MAY 27, 2022.

Allegations: EUREX DEUTSCHLAND ("EUREX") FOUND THAT, FROM JULY 2021 THROUGH OCTOBER 2021, DEUTSCHE BANK AG, FRANKFURT AM MAIN ("DB AG") FAILED TO CONVERT 7,257 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 72 OF THE EUREX EXCHANGE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. Status: Final Sanction Detail: EUREX ISSUED A REPRIMAND TO DB AG, BUT DID NOT IMPOSE A FINE OR OTHER MONETARY SANCTION. Summary: ON JUNE 29, 2022, DB AG RECEIVED A DECISION FROM EUREX FINDING THAT, FROM JULY 2021 THROUGH OCTOBER 2021, DB AG FAILED TO CONVERT 7,257 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 72 OF THE EUREX EXCHANGE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014, AND ISSUING A REPRIMAND TO DB AG, BUT NOT IMPOSING A FINE OR OTHER MONETARY SANCTION.

Allegations: THE FRANKFURT STOCK EXCHANGE ("FSE") FOUND THAT, FROM NOVEMBER 2021 THROUGH AUGUST 2022, DEUTSCHE BANK AG, FRANKFURT AM MAIN ("DB AG") FAILED TO CONVERT 2,038 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. Status: Final Sanction Detail: FSE ISSUED A REPRIMAND TO DB AG, BUT DID NOT IMPOSE A FINE OR OTHER MONETARY SANCTION. Summary: ON SEPTEMBER 2, 2023, DB AG RECEIVED A DECISION FROM FSE FINDING THAT, FROM NOVEMBER 2021 THROUGH AUGUST 2022, DB AG FAILED TO CONVERT 2,038 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014, AND ISSUING A REPRIMAND TO DB AG, BUT NOT IMPOSING A FINE OR OTHER MONETARY SANCTION.

Allegations: EUREX DEUTSCHLAND ("EUREX") FOUND THAT, IN NOVEMBER 2023, DEUTSCHE BANK AG, FRANKFURT AM MAIN ("DB AG") FAILED TO CONVERT 16 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 72 OF THE EUREX EXCHANGE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. Status: Final Sanction Detail: EUREX ISSUED A REPRIMAND TO DB AG, BUT DID NOT IMPOSE A FINE OR OTHER MONETARY SANCTION. Summary: ON JUNE 25, 2024, DB AG RECEIVED A DECISION DATED JUNE 10, 2024 FROM EUREX FINDING THAT, IN NOVEMBER 2023, DB AG FAILED TO CONVERT 16 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 72 OF THE EUREX EXCHANGE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014, AND ISSUING A REPRIMAND TO DB AG, BUT NOT IMPOSING A FINE OR OTHER MONETARY SANCTION.

Allegations: ON JANUARY 30, 2017, THE FINANCIAL CONDUCT AUTHORITY ("FCA") ENTERED A FINAL NOTICE UNDER PRINCIPLE 3 (MANAGEMENT AND CONTROL) AND SENIOR MANAGEMENT ARRANGEMENTS, SYSTEMS AND CONTROLS (SYSC) RULES 6.1.1 R AND 6.3.1 R BETWEEN JANUARY 1, 2012 AND DECEMBER 31, 2015 (THE RELEVANT PERIOD). SPECIFICALLY, THE FCA FOUND THAT WITH RESPECT TO DBAG, THE AML CONTROL FRAMEWORK WAS SUBSTANTIALLY INADEQUATE, AND THE RISKS RAISED WERE HIGHLIGHTED BY CERTAIN TRADING ARRANGED BY DEUTSCHE BANK'S RUSSIA-BASED SUBSIDIARY (DB MOSCOW) AND BOOKED TO DEUTSCHE BANK'S TRADING BOOKS IN LONDON. THE FCA FOUND THAT THE WAY THESE TRADES WERE CONDUCTED IN COMBINATION WITH THEIR SCALE AND VOLUME WERE HIGHLY SUGGESTIVE OF FINANCIAL CRIME. THE FCA FOUND THAT THE SUSPICIOUS SECURITIES TRADES, WHICH IT REFERRED TO AS "MIRROR TRADES," WERE USED BY CUSTOMERS OF DEUTSCHE BANK AND DB MOSCOW THAT WERE CONNECTED TO EACH OTHER TO TRANSFER MORE THAN USD 6 BILLION FROM RUSSIA, THROUGH DEUTSCHE BANK IN THE UK, TO OVERSEAS BANK ACCOUNTS. THE ORDERS FOR BOTH SIDES OF THE MIRROR TRADES WERE RECEIVED BY DB MOSCOW, WHICH EXECUTED BOTH SIDES AT THE SAME TIME. THE FCA FOUND THAT DBAG BREACHED PRINCIPLE 3 AND SYSC RULES 6.1.1. R AND 6.3.1 R IN THAT, DURING THE RELEVANT PERIOD, IN ITS CORPORATE BANKING & SECURITIES DIVISION BUSINESS, (1) ITS "CUSTOMER DUE DILIGENCE ("CDD") AND ENHANCED DUE DILIGENCE ("EDD") WAS INADEQUATE IN THAT IT FAILED TO OBTAIN SUFFICIENT INFORMATION ABOUT ITS CUSTOMERS TO INFORM THE RISK ASSESSMENT PROCESS AND TO PROVIDE A BASIS FOR TRANSACTION MONITORING; (2) ITS CULTURE FAILED TO INSTILL A SENSE OF RESPONSIBILITY IN THE FRONT OFFICE BUSINESS FOR THE IDENTIFICATION AND MANAGEMENT OF NON-FINANCIAL RISKS, PARTICULARLY IN THE LONDON FRONT OFFICE, WHICH FAILED TO APPRECIATE THAT IT WAS ULTIMATELY RESPONSIBLE FOR DEUTSCHE BANK'S KYC OBLIGATIONS; (3) IT USED FLAWED AML CUSTOMER AND COUNTRY RISK RATING METHODOLOGIES WHICH MEANT THAT CUSTOMERS WERE ASSIGNED INAPPROPRIATE RISK RATINGS; (4) ITS AML POLICIES AND PROCEDURES WERE DEFICIENT; (5) ITS AML IT INFRASTRUCTURE WAS INADEQUATE AND FAILED TO PROVIDE A SINGLE AUTHORITATIVE REPOSITORY OF KYC INFORMATION; (6) IT LACKED AUTOMATED AML SYSTEMS FOR DETECTING SUSPICIOUS TRADES AND LACKED AN EFFECTIVE SYSTEM FOR MONITORING MONEY FLOWS ASSOCIATED WITH TRANSACTIONS; AND (7) IT FAILED TO PROVIDE ADEQUATE OVERSIGHT OF TRADES BOOKED IN THE UK BY THE MOSCOW FRONT OFFICE AS WELL AS OTHER NON-UK TRANSACTIONS. Status: Final Sanction Detail: THE ORDER REQUIRED DBAG TO PAY A FINANCIAL PENALTY IN THE AMOUNT OF £163,076,224, WHICH THE BANK PAID ON FEBRUARY 1, 2017 Summary: DBAG CONSENTED TO THE ENTRY OF THE FINAL NOTICE ON JANUARY 30, 2017 BY THE FCA, PURSUANT TO WHICH DBAG SHALL PAY A CIVIL MONETARY PENALTY OF £163,076,224, WHICH DBAG PAID ON FEBRUARY 1, 2017.

Allegations: ON JANUARY 30, 2017, THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES, DBAG AND DBAG'S NEW YORK BRANCH ENTERED INTO A CONSENT ORDER UNDER NEW YORK BANKING LAW §§ 33, 44 AND 44-A. SPECIFICALLY, THE DFS FOUND THAT DBAG SUFFERED FROM SERIOUS COMPLIANCE DEFICIENCIES THAT ALLOWED CERTAIN BANK TRADERS AND OFFSHORE ENTITIES TO IMPROPERLY AND COVERTLY TRANSFER MORE THAN $10 BILLION OUT OF RUSSIA, BY USING THE SERVICES OF DEUTSCHE BANK OPERATIONS IN MOSCOW, LONDON AND NEW YORK TO CONVERT RUBLES INTO DOLLARS THROUGH SECURITY TRADES THAT HAD NO DISCERNABLE ECONOMIC PURPOSE. THE DFS FOUND THAT DBAG AND DBAG'S NEW YORK BRANCH CONDUCTED THEIR BANKING BUSINESS IN AN UNSAFE AND UNSOUND MANNER, IN VIOLATION OF NEW YORK BANKING LAW §§ 44, 44-A, FAILED TO MAINTAIN AN EFFECTIVE MONEY LAUNDERING PROGRAM, IN VIOLATION OF 3 N.Y.C.R.R. § 116.2, AND FAILED TO MAINTAIN AND MAKE AVAILABLE TRUE AND ACCURATE BOOKS, ACCOUNTS AND RECORDS REFLECTING ALL TRANSACTIONS AND ACTIONS, IN VIOLATION OF NEW YORK BANKING LAW § 200-C. Status: Final Sanction Detail: THE ORDER REQUIRED DBAG TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $425 MILLION, WHICH THE FIRM PAID ON FEBRUARY 3, 2017. Summary: DBAG AND DBAG'S NEW YORK BRANCH CONSENTED TO THE ENTRY OF THE ORDER ON JANUARY 30, 2017 BY THE DFS, PURSUANT TO WHICH DBAG AND DBAG'S NEW YORK BRANCH: (A) SHALL PAY A CIVIL MONETARY PENALTY OF $425 MILLION, WHICH DBAG PAID ON FEBRUARY 3, 2017; AND (B) ENGAGE AN INDEPENDENT MONITOR WITHIN 60 DAYS OF THE ORDER TO CONDUCT A COMPREHENSIVE REVIEW OF EXISTING BSA/AML COMPLIANCE PROGRAMS, POLICIES AND PROCEDURES IN PLACE AT THE BANK THAT PERTAIN TO OR AFFECT ACTIVITIES CONDUCTED BY OR THROUGH (A) DEUTSCHE BANK TRUST COMPANY AMERICAS AND (B) DBAG'S NEW YORK BRANCH, RECOMMEND CORRECTIVE ACTIONS, AND OVERSEE THE IMPLEMENTATION OF CORRECTIVE ACTIONS THE DFS DEEMS NECESSARY.

Allegations: ON APRIL 20, 2017, THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM AND DBAG ENTERED INTO A CONSENT ORDER PURSUANT TO SECTION 8 OF THE FEDERAL DEPOSIT INSURANCE ACT (12 U.S.C. § 1818) FOR FAILURE TO COMPLY WITH SECTION 13 OF THE BANK HOLDING COMPANY ACT OF 1956 (12 U.S.C. 1851) AND THE REGULATIONS THEREUNDER (THE "VOLCKER RULE"). SPECIFICALLY, THE FEDERAL RESERVE DETERMINED THAT, AS A RESULT OF THE DEFICIENCIES IDENTIFIED IN THE ORDER, DBAG HAD NOT IMPLEMENTED A COMPLIANCE PROGRAM REASONABLY DESIGNED TO ENSURE AND MONITOR COMPLIANCE WITH VOLCKER RULE REQUIREMENTS AND HAD ENGAGED IN UNSAFE OR UNSOUND BANKING PRACTICES AND VIOLATED PROVISIONS OF THE VOLCKER RULE. Status: Final Sanction Detail: THE ORDER REQUIRED DBAG TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $19.71 MILLION, WHICH DBAG PAID ON APRIL 20, 2017. Summary: DBAG CONSENTED TO THE ENTRY OF THE ORDER ON APRIL 20, 2017 BY THE FEDERAL RESERVE, PURSUANT TO WHICH DBAG: (A) WAS REQUIRED TO PAY A CIVIL MONETARY PENALTY OF $19.71 MILLION, WHICH DBAG PAID ON APRIL 20, 2017; AND (B) SUBMIT (1) A WRITTEN PLAN TO IMPROVE SENIOR MANAGEMENT'S OVERSIGHT OF DBAG'S COMPLIANCE WITH VOLCKER RULE REQUIREMENTS AND (2) AN ENHANCED WRITTEN INTERNAL CONTROLS AND COMPLIANCE RISK MANAGEMENT PROGRAM TO COMPLY WITH THE VOLCKER RULE, IN EACH CASE ACCEPTABLE TO THE FEDERAL RESERVE BANK OF NEW YORK.

Allegations: ON APRIL 20, 2017, THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "FED"), DBAG, DB USA CORPORATION AND DBAG'S NEW YORK BRANCH (COLLECTIVELY, "THE BANK") ENTERED INTO A CONSENT ORDER. ALTHOUGH THE FED ACKNOWLEDGED THAT THE BANK "FULLY COOPERATED" WITH THE FED AND "HAS MADE AND CONTINUES TO MAKE PROGRESS IN IMPLEMENTING ENHANCEMENTS TO ITS FIRM-WIDE COMPLIANCE SYSTEMS AND CONTROLS", THE FED FOUND THAT DURING THE REVIEW PERIOD FROM OCTOBER 2008 THROUGH OCTOBER 2013, THE BANK LACKED ADEQUATE GOVERNANCE, RISK MANAGEMENT, COMPLIANCE AND AUDIT POLICIES AND PROCEDURES TO ENSURE THAT THE BANK'S FOREIGN EXCHANGE ACTIVITIES COMPLIED WITH SAFE AND SOUND BANKING PRACTICES AND APPLICABLE INTERNAL POLICIES, WHICH PREVENTED THE BANK FROM DETECTING AND ADDRESSING UNSAFE AND UNSOUND CONDUCT BY CERTAIN OF ITS FX TRADERS. AS A RESULT OF THIS CONDUCT, THE FED FOUND THAT THE BANK ENGAGED IN UNSAFE AND UNSOUND BANKING PRACTICES. Status: Final Sanction Detail: THE ORDER REQUIRED THE BANK TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $136,950,000, WHICH THE BANK PAID ON APRIL 20, 2017. Summary: THE BANK CONSENTED TO THE ENTRY OF THE ORDER ON APRIL 20, 2017 BY THE FED, PURSUANT TO WHICH THE BANK: (A) SHALL PAY A CIVIL MONETARY PENALTY OF $136,950,000, WHICH THE BANK PAID ON APRIL 20, 2017; (B) SHALL SUBMIT WRITTEN PLANS TO IMPROVE SENIOR MANAGEMENT OVERSIGHT AND THE COMPLIANCE RISK MANAGEMENT PROGRAM, AN ENHANCED WRITTEN INTERNAL CONTROLS AND COMPLIANCE PROGRAM, AND AN ENHANCED WRITTEN INTERNAL AUDIT PROGRAM TO THE FED WITHIN 90 DAYS OF THE ORDER; (C) SHALL CONDUCT PERIODIC MONITORING BY SENIOR MANAGEMENT, AN ANNUAL REVIEW OF COMPLIANCE POLICIES AND PROCEDURES AND THEIR IMPLEMENTATION AND AN APPROPRIATE RISK-FOCUSED SAMPLING OF OTHER KEY CONTROLS, AND A FIRM-WIDE RISK ASSESSMENT TO EVALUATE CURRENT POTENTIAL CONDUCT RISKS; (D) FOR SUB-SECTIONS B & C, SHALL ADOPT AND PROMPTLY IMPLEMENT THE APPROVED PLANS AND PROGRAMS WITHIN 10 DAYS OF APPROVAL BY THE FED AND THEREAFTER FULLY COMPLY WITH THEM; AND (E) SHALL SUBMIT QUARTERLY WRITTEN PROGRESS REPORTS TO THE FED.

Allegations: THE SOUTH AFRICAN RESERVE BANK ("SARB") FOUND THAT DEUTSCHE BANK AG ("DB AG"), JOHANNESBURG BRANCH, IN CONNECTION WITH ITS ANTI-MONEY LAUNDERING ("AML") AND COUNTER-FINANCING OF TERRORISM ("CFT") COMPLIANCE PROGRAM, FAILED TO COMPLY WITH CERTAIN RESPONSIBILITIES AND REQUIREMENTS RELATING TO DB AG'S RISK MANAGEMENT AND COMPLIANCE PROGRAM, CUSTOMER DUE DILIGENCE, RECORDKEEPING, AND GOVERNANCE. Status: Final Sanction Detail: THE SARB IMPOSED A FINE OF ZAR 38 MILLION, WHICH IS APPROXIMATELY USO $2.60 MILLION, OF WHICH ZAR 28 MILLION (APPROXIMATELY USO $1.92 MILLION) WAS TIMELY PAID ON MARCH 23, 2021, AND OF WHICH ZAR 10 MILLION (APPROXIMATELY USO $690,000) IS SUSPENDED FOR THREE YEARS PROVIDED THERE ARE NO SIMILAR RECORDKEEPING DEFICIENCIES WITHIN THE THREE-YEAR PERIOD. Summary: ON FEBRUARY 26, 2021, THE SARB ENTERED AN ORDER (THE "ORDER") FINDING THAT DB AG, JOHANNESBURG BRANCH, IN CONNECTION WITH ITS AML COMPLIANCE PROGRAM, FAILED TO COMPLY WITH (I) RISK MANAGEMENT AND COMPLIANCE RESPONSIBILITIES, FOR EXAMPLE, BY FAILING TO IDENTIFY CERTAIN NATURAL-PERSON UBOS, (II) CUSTOMER DUE DILIGENCE REQUIREMENTS FOR CERTAIN CLIENTS, (III) RECORDKEEPING REQUIREMENTS FOR CERTAIN TERMINATED CLIENT RELATIONSHIPS, AND (IV) AML/CFT GOVERNANCE REQUIREMENTS RELATING TO CUSTOMER DUE DILIGENCE, RECORDKEEPING, AND SCREENING PROCESSES FOR EXISTING CUSTOMERS. THE SARB ISSUED CAUTIONS, A REPRIMAND, AND A FINE OF ZAR 38 MILLION, WHICH IS APPROXIMATELY USD $2.60 MILLION, OF WHICH ZAR 28 MILLION (APPROXIMATELY USD $690,000) IS SUSPENDED FOR THREE YEARS PROVIDED THERE ARE NO SIMILAR RECORDKEEPING DEFICIENCIES WITHIN THE THREE-YEAR PERIOD.

Allegations: THE CZECH NATIONAL BANK ("CNB") FOUND THAT DEUTSCHE BANK AG ("DB AG"), PRAGUE BRANCH FAILED TO IMPLEMENT AND APPLY APPROPRIATE INTERNAL CONTROL PROCEDURES TO MITIGATE RISKS RELATING TO ANTI-MONEY LAUNDERING AND TERRORIST FINANCING BY FAILING TO VERIFY CERTAIN CLIENT DATA AGAINST SANCTION LISTS, ESTABLISHING UNREASONABLY LONG DEADLINES FOR CHECKING POTENTIALLY SUSPICIOUS TRANSACTION ALERTS, AND FAILING TO ENSURE THAT CONTROL PROCEDURES COULD BE ADEQUATELY RECONSTRUCTED. IN ADDITION, THE CNB FOUND THAT DB AG, PRAGUE BRANCH FAILED TO PERFORM CLIENT CHECKS TO THE EXTENT NECESSARY TO ASSESS SUCH RISKS BY SETTING INADEQUATE PARAMETERS FOR THE GENERATION OF SUSPICIOUS TRANSACTION ALERTS, AND IN AT LEAST ONE CASE, FAILING TO FLAG CROSS-BORDER TRANSACTIONS THAT DID MEET THE PARAMETERS. Status: Final Sanction Detail: THE CNB IMPOSED A FINE OF FIVE MILLION CZECH CROWNS, WHICH IS APPROXIMATELY USD $225,000, WHICH WILL BE TIMELY PAID. Summary: ON MARCH 10, 2021, THE CNB ENTERED AN ORDER (THE "ORDER") FINDING THAT DB AG, PRAGUE BRANCH FAILED TO IMPLEMENT AND APPLY APPROPRIATE INTERNAL CONTROL PROCEDURES TO MITIGATE RISKS RELATING TO ANTI-MONEY LAUNDERING AND TERRORIST FINANCING BY FAILING TO ENTER IDENTIFICATION DATA INTO ITS INTERNAL SYSTEM TO VERIFY CERTAIN CLIENT DATA AGAINST SANCTION LISTS, ESTABLISHING UNREASONABLY LONG DEADLINES FOR CHECKING POTENTIALLY SUSPICIOUS TRANSACTION ALERTS, AND FAILING TO ENSURE THAT CONTROL PROCEDURES COULD BE ADEQUATELY RECONSTRUCTED. IN ADDITION, THE CNB FOUND THAT DB AG, PRAGUE BRANCH FAILED TO PERFORM CLIENT CHECKS TO THE EXTENT NECESSARY TO ASSESS RISKS RELATING TO ANTI-MONEY LAUNDERING AND TERRORIST FINANCING BY SETTING INADEQUATE PARAMETERS FOR THE GENERATION OF SUSPICIOUS TRANSACTION ALERTS, AND IN AT LEAST ONE CASE, FAILING TO FLAG CROSS-BORDER TRANSACTIONS THAT DID MEET THE PARAMETERS FOR THE GENERATION OF SUSPICIOUS TRANSACTION ALERTS. THE CNB IMPOSED A FINE OF FIVE MILLION CZECH CROWNS, WHICH IS APPROXIMATELY USD $225,000, WHICH WILL BE TIMELY PAID.

Allegations: THE RESERVE BANK OF INDIA ("RBI") FOUND THAT DEUTSCHE BANK AG ("DB AG") FAILED TO OFFER UNIFORM RATES OF INTEREST PAID ON DEPOSITS OF SIMILAR AMOUNT AND TENURE ACCEPTED ON THE SAME DATES IN SEVEN INSTANCES FROM FINANCIAL YEARS 2017 TO 2019. IN ADDITION, THE RBI FOUND THAT DB AG COMMUNICATED INTEREST RATES OF BULK DEPOSITS BEFORE PUBLISHING THE INTEREST RATE SCHEDULE ON ITS WEBSITE, AND FAILED TO MAINTAIN THE BULK DEPOSIT INTEREST RATE CARD FOR CORPORATE CUSTOMERS IN ITS CORE BANKING SYSTEM PRIOR TO JULY 20, 2020. Status: Final Sanction Detail: THE RBI IMPOSED A FINE OF TWO CORE RUPEES, WHICH IS APPROXIMATELY $276,000, WHICH WAS TIMELY PAID JANUARY 19, 2021. Summary: ON JANUARY 12, 2021, THE RBI ENTERED AN ORDER {THE "ORDER") FINDING THAT DB AG FAILED TO OFFER UNIFORM RATES OF INTEREST PAID ON DEPOSITS OF SIMILAR AMOUNT AND TENURE ACCEPTED ON THE SAME DATES IN SEVEN INSTANCES FROM FINANCIAL YEARS 2017 TO 2019. IN ADDITION, THE RBI FOUND THAT DB AG COMMUNICATED INTEREST RATES OF BULK DEPOSITS BEFORE PUBLISHING THE INTEREST RATE SCHEDULE ON ITS WEBSITE, AND FAILED TO MAINTAIN THE BULK DEPOSIT INTEREST RATE CARD FOR CORPORATE CUSTOMERS IN ITS CORE BANKING SYSTEM PRIOR TO JULY 20, 2020. THE RBI IMPOSED A FINE OF TWO CORE RUPEES, WHICH IS APPROXIMATELY $276,000, WHICH WAS TIMELY PAID ON JANUARY 19, 2021.

Allegations: IN A CONSENT ORDER DATED JULY 7, 2020 (THE "CONSENT ORDER"), THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ("NY DFS") FOUND THAT DEUTSCHE BANK AG ("DBAG"), DBAG NEW YORK BRANCH (THE "NY BRANCH"), AND DEUTSCHE BANK TRUST COMPANY AMERICAS ("DBTCA," TOGETHER WITH DBAG AND THE NY BRANCH, "DEUTSCHE BANK" OR THE "BANK"), IN CONNECTION WITH THE BANK'S FORMER RELATIONSHIP WITH JEFFREY EPSTEIN AND FORMER CORRESPONDENT BANKING RELATIONSHIPS WITH DANSKE BANK A/S ESTONIA BRANCH ("DANSKE ESTONIA") AND THE FEDERAL BANK OF THE MIDDLE EAST LTD. ("FBME"), CONDUCTED BUSINESS IN AN UNSAFE AND UNSOUND MANNER AND FAILED TO MAINTAIN AN EFFECTIVE AND COMPLIANT ANTI-MONEY LAUNDERING PROGRAM. NY DFS FOUND THAT THE BANK FAILED TO ADEQUATELY MONITOR THE ACTIVITY OF MR. EPSTEIN AND HIS RELATED ENTITIES BETWEEN AUGUST 2013 AND DECEMBER 2018 DESPITE DEEMING MR. EPSTEIN A "HIGH RISK" CLIENT, THEREBY FAILING TO DETECT AND PREVENT SUSPICIOUS TRANSACTIONS. IN CONNECTION WITH THE BANK'S CORRESPONDENT BANKING RELATIONSHIP WITH FBME (TERMINATED IN JULY 2014), NY DFS FOUND THAT THE HIGH-RISK NATURE OF THE RELATIONSHIP, THE HIGH NUMBER OF SUSPICIOUS TRANSACTIONS, AND OTHER AML-RELATED ISSUES SHOULD HAVE PROMPTED THE BANK TO EXIT THE RELATIONSHIP BEFORE THE U.S. TREASURY DEPARTMENT'S FINANCIAL CRIMES ENFORCEMENT NETWORK NAMED FBME AS A FOREIGN FINANCIAL INSTITUTION OF PRIMARY MONEY LAUNDERING CONCERN IN JULY 2014. IN CONNECTION WITH THE BANK'S CORRESPONDENT BANKING RELATIONSHIP WITH DANSKE ESTONIA (TERMINATED IN OCTOBER 2015), NY DFS FOUND THAT THE BANK CONTINUED ITS RELATIONSHIP WITH DANSKE ESTONIA DESPITE THE HIGH NUMBER OF SUSPICIOUS TRANSACTIONS, THE HISTORY OF HIGH-RISK SCORES THE BANK ASSIGNED TO DANSKE ESTONIA, AND THE BANK'S DISCUSSIONS WITH DANSKE ESTONIA ABOUT DANSKE ESTONIA'S AML POLICIES AND CONTROLS. Status: Final Sanction Detail: DEUTSCHE BANK AGREED TO COOPERATE WITH AN INDEPENDENT MONITOR APPOINTED PURSUANT TO A PRIOR CONSENT ORDER WITH THE NY DFS, DATED JANUARY 30, 2017; TO ADDRESS THE COMPLIANCE FAILURES ALLEGED IN THE CONSENT ORDER WITHIN THE TIMETABLES OF THE PRIOR CONSENT ORDER; TO PAY A CIVIL MONEY PENALTY OF $150,000,000, WHICH WAS TIMELY PAID ON JULY 10, 2020, AND TO COOPERATE WITH THE NY DFS REGARDING THE TERMS OF THE CONSENT ORDER. Summary: ON JULY 7, 2020, DEUTSCHE BANK ENTERED INTO A SETTLEMENT WITH THE NY DFS. THAT SETTLEMENT IS REFLECTED IN A CONSENT ORDER ISSUED BY THE NY DFS UNDER NEW YORK BANKING LAW §§ 39 AND 44 (THE "CONSENT ORDER"). THE CONSENT ORDER REQUIRED THE BANK TO CONTINUE TO COOPERATE WITH AN INDEPENDENT MONITOR APPOINTED PURSUANT TO A PRIOR CONSENT ORDER WITH THE NY DFS, DATED JANUARY 30, 2017; TO ADDRESS THE COMPLIANCE FAILURES ALLEGED IN THE CONSENT ORDER WITHIN THE TIMETABLES OF THE PRIOR CONSENT ORDER; TO PAY A CIVIL MONEY PENALTY OF $150,000,000, WHICH WAS TIMELY PAID ON JULY 10, 2020, AND TO COOPERATE WITH THE NY DFS REGARDING THE TERMS OF THE CONSENT ORDER.

Allegations: THE BANK OF PORTUGAL ALLEGED THAT THREE EMPLOYEES AT A BRANCH AGENCY OF DEUTSCHE BANK AG-PORTUGAL BRANCH ("DB AG PORTUGAL") HAD NOT COMPLETED REQUIRED TRAINING FOR MANAGING CASH (EURO BANKNOTES AND COINS). THE BANK OF PORTUGAL FURTHER ALLEGED THAT DB AG PORTUGAL THUS MADE EURO NOTES AVAILABLE TO THE PUBLIC THAT WERE NOT VERIFIED BY PROFESSIONALS PROPERLY QUALIFIED TO VERIFY AUTHENTICITY AND QUALITY. Status: Final Sanction Detail: DB AG PORTUGAL AGREED TO THE BANK OF PORTUGAL'S IMPOSITION OF A FINE OF 6,000 EUROS, WHICH IS APPROXIMATELY USD $7,000. THE FINE WAS TIMELY PAID ON OCTOBER 19, 2021. Summary: ON OCTOBER 19, 2021, DB AG PORTUGAL SUBMITTED A DECLARATION OF ACCEPTANCE OF A DECISION ISSUED BY THE BANK OF PORTUGAL ALLEGING THAT THREE EMPLOYEES AT A BRANCH AGENCY OF DB AG PORTUGAL HAD NOT COMPLETED REQUIRED TRAINING FOR MANAGING CASH (EURO BANKNOTES AND COINS). THE BANK OF PORTUGAL FURTHER ALLEGED THAT DB AG PORTUGAL THUS MADE EURO NOTES AVAILABLE TO THE PUBLIC THAT WERE NOT VERIFIED BY PROFESSIONALS PROPERLY QUALIFIED TO VERIFY AUTHENTICITY AND QUALITY. PURSUANT TO THE DECLARATION OF ACCEPTANCE, DB AG PORTUGAL AGREED TO A FINE OF 6,000 EUROS, WHICH IS APPROXIMATELY USD $7,000. THE FINE WAS TIMELY PAID ON OCTOBER 19, 2021.

Allegations: THE SWISS FEDERAL DEPARTMENT OF FINANCE (THE "SWISS EFD") FOUND THAT DEUTSCHE BANK AG ("DB AG") FAILED TO MAKE TIMELY REPORTS TO THE SIX SWISS EXCHANGE ("SIX") WHEN DB AG'S HOLDINGS OF TWO SIX-LISTED COMPANIES HAD FALLEN BELOW THE THRESHOLD REQUIRING NOTIFICATION TO THE SIX WITHIN FOUR TRADING DAYS. IN ADDITION, THE SWISS EFD FOUND THAT DB AG FAILED TO CORRECT INACCURATE DISCLOSURE REPORTS RELATING TO ITS HOLDINGS IN ANOTHER SIX-LISTED COMPANY. Status: Final Sanction Detail: THE SWISS EFD IMPOSED A FINE OF 30,000 SWISS FRANCS, WHICH IS APPROXIMATELY USD $33,000, WHICH WILL BE TIMELY PAID. Summary: ON JUNE 4, 2021, THE SWISS EFD ENTERED AN ORDER (THE "ORDER") FINDING THAT DB AG FAILED TO MAKE TIMELY REPORTS TO THE SIX SWISS EXCHANGE ("SIX") WHEN DB AG'S HOLDINGS OF TWO SIX-LISTED COMPANIES HAD FALLEN BELOW THE THRESHOLD REQUIRING NOTIFICATION TO THE SIX WITHIN FOUR TRADING DAYS. IN ADDITION, THE SWISS EFD FOUND THAT DB AG FAILED TO CORRECT INACCURATE DISCLOSURE REPORTS RELATING TO ITS HOLDINGS IN ANOTHER SIX-LISTED COMPANY. THE SWISS EFD IMPOSED A FINE OF THIRTY THOUSAND SWISS FRANCS, WHICH IS APPROXIMATELY USD $33,000, WHICH WILL BE TIMELY PAID.

Allegations: THE STATE BANK OF PAKISTAN ("SBP") FOUND THAT IN 2011, DEUTSCHE BANK AG ("DB AG"), THROUGH ITS KARACHI BRANCH, FAILED TO REPORT DISBURSEMENT OF, AND INTEREST CHARGED ON, CERTAIN LOANS TO THE SBP IN MONTHLY FOREIGN EXCHANGE RETURNS AS REQUIRED BY FOREIGN EXCHANGE CIRCULAR LETTER NO. 5. Status: Final Sanction Detail: DB AG AGREED TO AN ADMINISTRATIVE PENALTY OF PKR 1,030,000, WHICH IS APPROXIMATELY USD $5,682, WHICH WILL BE TIMELY PAID. Summary: ON FEBRUARY 28, 2022, DB AG RECEIVED AN ORDER FROM THE SBP, FINDING THAT IN 2011, DB AG, THROUGH ITS KARACHI BRANCH, FAILED TO REPORT DISBURSEMENT OF, AND INTEREST CHARGED ON, CERTAIN LOANS TO THE SBP IN MONTHLY FOREIGN EXCHANGE RETURNS AS REQUIRED BY FOREIGN EXCHANGE CIRCULAR LETTER NO. 5. THE SBP IMPOSED AN ADMINISTRATIVE PENALTY OF PKR 1,030,000 WHICH IS APPROXIMATELY USD $5,682, WHICH WILL BE TIMELY PAID.

Allegations: THE GERMAN FEDERAL FINANCIAL SUPERVISORY AUTHORITY ("BAFIN") ALLEGED THAT FROM APRIL 24, 2019 TO APRIL 23, 2020, DEUTSCHE BANK AG ("DB AG"), AS A SUPERVISED CONTRIBUTOR TO THE EURIBOR BENCHMARK RATE, DID NOT HAVE SUFFICIENTLY EFFECTIVE CONTROLS FOR THE SUBMISSION OF DATA PURSUANT TO ARTICLE 16(2)(A) OF THE REGULATION (EU) 2016/1011 (EU BENCHMARK REGULATION). Status: Final Sanction Detail: DB AG AGREED TO A FINE OF 8,663,200 EUROS, WHICH IS APPROXIMATELY USD $9,800,000, WHICH WAS TIMELY PAID ON JANUARY 14, 2022. Summary: ON DECEMBER 28, 2021, DB AG RECEIVED A FINE NOTICE IN CONNECTION WITH A REGULATORY SETTLEMENTWITH BAFIN. BAFIN ALLEGED THAT FROM APRIL 24, 2019 TO APRIL 23, 2020, DB AG, AS A SUPERVISED CONTRIBUTOR TO THE EURIBOR BENCHMARK RATE, DID NOT HAVE SUFFICIENTLY EFFECTIVE CONTROLS FORTHE SUBMISSION OF DATA PURSUANT TO ARTICLE 16(2)(A) OF THE REGULATION (EU) 2016/1011 (EUBENCHMARK REGULATION). DB AG AGREED TO A FINE OF 8,663,200 EUROS, WHICH IS APPROXIMATELY USD$9,800,000, WHICH WAS TIMELY PAID ON JANUARY 14, 2022.

Allegations: THE FRANKFURT STOCK EXCHANGE ("FSE") FOUND THAT, FROM MAY 2023 THROUGH JUNE 2023, DEUTSCHE BANK AG, FRANKFURT AM MAIN ("DB AG") FAILED TO CONVERT 169 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 PARA 3 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. Status: Final Sanction Detail: THE DECISION DID NOT IMPOSE A FINE OR OTHER MONETARY SANCTION. Summary: ON JULY 9, 2024, DB AG RECEIVED A DECISION FROM FSE FINDING THAT, FROM MAY 2023 THROUGH JUNE 2023, DB AG FAILED TO CONVERT 169 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 PARA 3 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. THE DECISION DID NOT IMPOSE A FINE OR OTHER MONETARY SANCTION.

Allegations: THE SECURITIES AND COMMODITIES AUTHORITY - UAE ("SCA") FOUND THAT DEUTSCHE BANK AG, DUBAI BRANCH (DEUTSCHE SECURITIES AND SERVICES) ("DSS") FAILED TO SUBMIT REQUIRED QUARTERLY AUDITOR-REVIEWED REPORTS FOR THE PERIOD ENDING SEPTEMBER 30, 2023. Status: Final Sanction Detail: THE ENFORCEMENT NOTICE IMPOSED A FINE ON DSS OF AED 10,000, WHICH IS APPROXIMATELY USD $2,750. DSS FILED AN APPEAL WITH SCA ON FEBRUARY 7, 2024, WHICH WAS REJECTED ON FEBRUARY 12, 2024. Summary: ON FEBRUARY 2, 2024, SCA ISSUED AN ENFORCEMENT NOTICE TO DSS, FINDING THAT DSS FAILED TO SUBMIT REQUIRED QUARTERLY AUDITOR-REVIEWED REPORTS FOR THE PERIOD ENDING SEPTEMBER 30, 2023. THE ENFORCEMENT NOTICE IMPOSED A FINE ON DSS OF AED 10,000, WHICH IS APPROXIMATELY USD $2,750. DSS FILED AN APPEAL WITH SCA ON FEBRUARY 7, 2024, WHICH WAS REJECTED ON FEBRUARY 12, 2024.

Allegations: THE FRANKFURT PUBLIC PROSECUTOR ("FPP") FOUND THAT, FROM 2017 TO 2022, DEUTSCHE BANK AG ("DBAG") FAILED TO TIMELY FILE CERTAIN SUSPICIOUS ACTIVITY REPORTS ("SARS") AS REQUIRED BY THE GERMAN MONEY LAUNDERING ACT. Status: Final Sanction Detail: DBAG AGREED TO A FINE OF 1,830,000 EUROS, WHICH IS APPROXIMATELY USD $1,965,000, WHICH WILL BE TIMELY PAID. Summary: ON FEBRUARY 22, 2023, THE FPP ISSUED A FINE NOTICE FINDING THAT, FROM 2017 TO 2022, DBAG FAILED TO TIMELY FILE CERTAIN SARS AS REQUIRED BY THE GERMAN MONEY LAUNDERING ACT. DBAG AGREED TO A FINE OF 1,830,000 EUROS, WHICH IS APPROXIMATELY USD $1,965,000, WHICH WILL BE TIMELY PAID.

Allegations: THE FRANKFURT STOCK EXCHANGE ("FSE") FOUND THAT, FROM SEPTEMBER 2022 THROUGH OCTOBER 2022, DEUTSCHE BANK AG, FRANKFURT AM MAIN ("DB AG") FAILED TO CONVERT 238 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. Status: Final Sanction Detail: THE FSE CLOSED THE PROCEEDING WITHOUT ANY SANCTIONS, REQUIRED DB AG TO PAY A FEE FOR THE PROCEEDING OF EUR 1,000 (APPROXIMATELY USD 1,100), WHICH WILL BE TIMELY PAID. Summary: ON AUGUST 1, 2024, DB AG RECEIVED A DECISION FROM FSE ISSUED ON JUNE 24, 2024 FINDING THAT, FROM SEPTEMBER 2022 THROUGH OCTOBER 2022, DB AG FAILED TO CONVERT 238 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. THE FSE CLOSED THE PROCEEDING WITHOUT ANY SANCTIONS, BUT REQUIRED DB AG TO PAY A FEE FOR THE PROCEEDING OF EUR 1,000 (APPROXIMATELY USD 1,100), WHICH WILL BE TIMELY PAID.

Allegations: THE NATI0NAL BANK OF HUNGARY ("NBH") FOUND THAT DEUTSCHE BANK AG, HUNGARY BRANCH ("DBAG") DID NOT MEET ITS DATA REPORTING OBLIGATIONS WITH APPROPRIATE DATA QUALITY RELATED TO SPECIFIC BALANCE SHEET ITEMS AND CASH FLOW REPORTS. Status: Final Sanction Detail: THE RESOLUTION IMPOSED A FINE ON DBAG OF 4,000,000 HUNGARIAN FORINTS, WHICH IS APPROXIMATELY USD $11,093, WHICH WAS TIMELY PAID ON JULY 21, 2023. Summary: ON JULY 11, 2023, THE NBH ISSUED A RESOLUTION AGAINST DBAG FINDING THAT DBAG DID NOT MEET ITS DATA REPORTING OBLIGATIONS WITH APPROPRIATE DATA QUALITY RELATED TO SPECIFIC BALANCE SHEET ITEMS AND CASH FLOW REPORTS. THE RESOLUTION IMPOSED A FINE ON DBAG OF 4,000,000 HUNGARIAN FORINTS, WHICH IS APPROXIMATELY USD $11,093, WHICH WAS TIMELY PAID ON JULY 21, 2023.

Allegations: THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ("FRB") ALLEGED THAT DEUTSCHE BANK AG, DEUTSCHE BANK AG NEW YORK BRANCH, DB USA CORPORATION, DEUTSCHE BANK TRUST COMPANY AMERICAS, AND DWS USA CORPORATION (COLLECTIVELY, THE "SETTLING ENTITIES" OR THE "BANK") INSUFFICIENTLY AND TARDILY IMPLEMENTED THE POST-SETTLEMENT SANCTIONS AND EMBARGOES AND AML CONTROL ENHANCEMENT UNDERTAKINGS REQUIRED BY PRIOR CONSENT ORDERS WITH THE FRB DATED NOVEMBER 4, 2015, AND MAY 26, 2017, RESPECTIVELY. Status: Final Sanction Detail: THE SETTLING ENTITIES, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AGREED TO A FINE OF $186,392,035, WHICH WAS TIMELY PAID ON JULY 14, 2023. Summary: ON JULY 13, 2023, THE FRB AND THE SETTLING ENTITIES ENTERED INTO A CONSENT ORDER RELATING TO ALLEGATIONS THAT THE SETTLING ENTITIES INSUFFICIENTLY AND TARDILY IMPLEMENTED THE POST-SETTLEMENT SANCTIONS AND EMBARGOES AND AML CONTROL ENHANCEMENT UNDERTAKINGS REQUIRED BY PRIOR CONSENT ORDERS WITH THE FRB DATED NOVEMBER 4, 2015, AND MAY 26, 2017, RESPECTIVELY. THE SETTLING ENTITIES, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AGREED TO A FINE OF $186,392,035, INCLUDING $140,192,035 FOR THE VIOLATIONS ALLEGED WITH RESPECT TO THE POST-SETTLEMENT SANCTIONS AND EMBARGOES AND AML CONTROL ENHANCEMENT UNDERTAKINGS, AS WELL AS A SEPARATE PENALTY OF $46,000,000 FOR UNSAFE OR UNSOUND PRACTICES STEMMING FROM THE BANK'S HANDLING OF ITS LEGACY CORRESPONDENT BANKING RELATIONSHIP WITH DANSKE BANK ESTONIA, WHICH WAS TERMINATED IN OCTOBER 2015. THE FINE WAS TIMELY PAID ON JULY 14, 2023. IN ADDITION, THE CONSENT ORDER INCLUDES CERTAIN POST-SETTLEMENT REMEDIATION AND REPORTING UNDERTAKINGS.

Allegations: THE SECURITIES AND COMMODITIES AUTHORITY - UAE ("SCA") FOUND THAT DEUTSCHE BANK AG, DUBAI BRANCH (DEUTSCHE SECURITIES AND SERVICES) ("DSS") FAILED TO TIMELY SUBMIT A REQUIRED ANNUAL FINANCIAL REPORT FOR THE PERIOD ENDING DECEMBER 31, 2023. Status: On Appeal Sanction Detail: THE ENFORCEMENT NOTICE IMPOSED A FINE ON DSS OF AED 50,000, WHICH IS APPROXIMATELY USD $13,613, WHICH WILL BE TIMELY PAID. Summary: ON JUNE 20, 2024, SCA ISSUED AN ENFORCEMENT NOTICE TO DSS DATED JUNE 10, 2024, FINDING THAT DSS FAILED TO TIMELY SUBMIT A REQUIRED ANNUAL FINANCIAL REPORT FOR THE PERIOD ENDING DECEMBER 31, 2023. THE PENALTY NOTICE IMPOSED A FINE ON DSS OF AED 50,000, WHICH IS APPROXIMATELY USD $13,613, WHICH WILL BE TIMELY PAID. DSS FILED AN APPEAL WITH SCA ON JUNE 27, 2024, WHICH REMAINS PENDING.

Allegations: THE CENTRAL BANK OF THE REPUBLIC OF CHINA (TAIWAN) ("CBC") FOUND THAT DEUTSCHE BANK AG, TAIPEI BRANCH ("DBTP") FAILED TO REVIEW TRANSACTIONAL DOCUMENTS TO VERIFY THAT ITS CLIENTS' TWD/FOREIGN CURRENCY FORWARD TRADES WERE DRIVEN BY "FOREIGN EXCHANGE GENUINE NEED" FOR TAIWAN DOLLARS, RESULTING IN THE CLIENTS ENGAGING IN SPECULATIVE TRADING IN TWD/FOREIGN CURRENCY FORWARDS. IN ADDITION, CERTAIN OF THOSE TRANSACTIONS, WHEN MATCHED WITH SPOT FX TRANSACTIONS UPON MATURITY OF THE FORWARD TRANSACTIONS, WERE FOUND TO BE IN THE NATURE OF SYNTHETIC NDF TRANSACTIONS WITH COUNTERPARTIES OTHER THAN THOSE ALLOWED BY CBC REGULATIONS. Status: Final Sanction Detail: BEGINNING ON FEBRUARY 8, 2021, DBTP'S AUTHORITY TO ENGAGE IN TWD/FOREIGN CURRENCY FORWARD TRADES AND TWD/FOREIGN CURRENCY NON-DELIVERABLE FORWARD TRADES WAS REVOKED. FOR A PERIOD OF TWO YEARS, ALSO BEGINNING FEBRUARY 8, 2021, DBTP IS SUSPENDED FROM ENGAGING IN FOREIGN EXCHANGE DERIVATIVES TRANSACTIONS. THE REVOCATION AND SUSPENSION WERE ISSUED IN A SANCTION LETTER TO DBTP ON FEBRUARY 5, 2021 (THE "SANCTION LETTER"), SUBJECT TO AN ADMINISTRATIVE APPEAL TO BE SUBMITTED WITHIN 31 DAYS FOLLOWING RECEIPT OF THE SANCTION LETTER. DBTP IS PERMITTED TO RE-APPLY TO THE CBC TO RESUME BUSINESS ACTIVITIES COVERED BY THE REVOCATION AND SUSPENSION PRIOR TO THE END OF THE TWO-YEAR PERIOD UPON DEMONSTRATION TO THE CBC OF "CONCRETE IMPROVEMENT." NO MONETARY SANCTION WAS IMPOSED BY THE CBC. Summary: ON FEBRUARY 5, 2021, THE CBC ISSUED THE SANCTION LETTER TO DBTP. IN THE SANCTION LETTER, THE CBC FOUND THAT DBTP FAILED TO REVIEW TRANSACTIONAL DOCUMENTS TO VERIFY THAT ITS CLIENTS' TWD/FOREIGN CURRENCY FORWARD TRADES WERE DRIVEN BY "FOREIGN EXCHANGE GENUINE NEED" FOR TAIWAN DOLLARS, RESULTING IN THE CLIENTS ENGAGING IN SPECULATIVE TRADING IN TWD/FOREIGN CURRENCY FORWARDS. IN ADDITION, CERTAIN OF THOSE TRANSACTIONS, WHEN MATCHED WITH SPOT FX TRANSACTIONS UPON MATURITY OF THE FORWARD TRANSACTIONS, WERE FOUND TO BE IN THE NATURE OF SYNTHETIC NDF TRANSACTIONS WITH COUNTERPARTIES OTHER THAN THOSE ALLOWED BY CBC REGULATIONS. THE SANCTION LETTER REVOKED DBTP'S ABILITY TO ENGAGE IN TWD/FOREIGN CURRENCY FORWARD TRADES AND TWD/FOREIGN CURRENCY NON-DELIVERABLE FORWARD TRADES, AND SUSPENDED DBTP FOR A PERIOD OF TWO YEARS FROM ENGAGING IN FOREIGN EXCHANGE DERIVATIVES TRANSACTIONS. THE REVOCATION AND SUSPENSION ARE SUBJECT TO AN ADMINISTRATIVE APPEAL TO BE SUBMITTED WITHIN 31 DAYS FOLLOWING RECEIPT OF THE SANCTION LETTER. DBTP IS PERMITTED TO RE-APPLY TO THE CBC TO RESUME BUSINESS ACTIVITIES COVERED BY THE REVOCATION AND SUSPENSION PRIOR TO THE END OF THE TWO-YEAR PERIOD UPON DEMONSTRATION TO THE CBC OF "CONCRETE IMPROVEMENT." NO MONETARY SANCTION WAS IMPOSED BY THE CBC.

Allegations: DEUTSCHE BANK AG WAS FOUND TO HAVE VIOLATED FCA BUSINESS PRINCIPLES 3, 5 AND 11 - MANAGEMENT AND CONTROL;- MARKET CONDUCT, AND RELATIONS WITH REGULATORS IN RELATION TO CONDUCT IN CONNECTION WITH LIBOR AND EURIBOR SUBMISSIONS AND FOR MISLEADING THE FCA DURING THE COURSE OF ITS REVIEW. Status: Final Sanction Detail: DBAG WAS ORDERED TO PAY A FINE OF 226,800,000.00 (GBP). THE FINE WAS PAID ON 5/5/15. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBAG AGREED TO PAY THE FINE OF $226,800,000 (GBP) THE FINE WAS PAID ON 5/5/15.

Allegations: DEUTSCHE BANK AG INCLUDING DEUTSCHE BANK AG NEW YORK BRANCH, WERE FOUND TO HAVE ENGAGED IN UNSAFE AND UNSOUND BANKING PRACTICES AND AGREED TO PAY $600 MILLION, ORDERED TO TERMINATE THE EMPLOYMENT OF SEVEN INDIVIDUALS (SIX EMPLOYEES BASED IN THE UK AND ONE BASED IN FRANKFURT) AND TO INSTALL A MONITOR FOR A PERIOD OF TWO YEARS, WHICH WILL OVERSEE THE BANK'S COMPLIANCE PROGRAMS. Status: Final Sanction Detail: DBAG WAS ORDERED TO PAY A FINE OF $600,000,000.00. THE FINE WAS PAID ON 5/1/15. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBAG AND DBAG (NY BRANCH) AGREED TO PAY THE FINE OF $600,000,000.00 THE FINE WAS PAID ON 5/1/15.

Allegations: THE FED INVESTIGATED WHETHER DBAG WAS INTENTIONALLY ALTERING OR REMOVING INFORMATION IDENTIFYING U.S.-SANCTIONED PARTIES IN USD WIRE TRANSFER INSTRUCTIONS SENT TO OR THROUGH THE UNITED STATES, OR IMPROPERLY USING COVER PAYMENTS, IN ORDER TO AVOID POSSIBLE REJECTION OR BLOCKING OF THOSE TRANSFERS BY U.S. BANKS, IN VIOLATION OF U.S. SANCTIONS AND OTHER LAWS AND REGULATIONS. THE NYSDFS INVESTIGATED WHETHER DBAG WAS INTENTIONALLY ALTERING OR REMOVING INFORMATION IDENTIFYING U.S.-SANCTIONED PARTIES IN USD WIRE TRANSFER INSTRUCTIONS SENT TO OR THROUGH THE UNITED STATES, OR IMPROPERLY USING COVER PAYMENTS, IN ORDER TO AVOID POSSIBLE REJECTION OR BLOCKING OF THOSE TRANSFERS BY U.S. BANKS, IN VIOLATION OF NEW YORK STATE LAWS, INCLUDING LAWS REQUIRING FINANCIAL INSTITUTIONS TO MAINTAIN ACCURATE BOOKS AND RECORDS. Status: Final Sanction Detail: DBAG AGREED TO PAY $258 MILLION IN PENALTIES AND COMPLY WITH REMEDIAL MEASURES TO IMPROVE COMPLIANCE WITH U.S. SANCTIONS AND ANTI-MONEY LAUNDERING LAWS. THE FED PENALTY WAS PAID ON NOVEMBER 3, 2015. THE NYSDFS PENALTY WAS PAID ON NOVEMBER 5, 2015. Summary: DBAG AGREED TO PAY $258 MILLION IN PENALTIES AND COMPLY WITH REMEDIAL MEASURES TO IMPROVE COMPLIANCE WITH U.S. SANCTIONS AND ANTI-MONEY LAUNDERING LAWS. THE FED PENALTY WAS PAID ON NOVEMBER 3, 2015. THE NYSDFS PENALTY WAS PAID ON NOVEMBER 5, 2015.

Allegations: THE GERMAN FEDERAL FINANCIAL SUPERVISORY AUTHORITY ("BAFIN") FOUND THAT DEUTSCHE BANK AG ("DBAG") FAILED TO INFORM BAFIN OF AN INFORMATION TECHNOLOGY SECURITY INCIDENT THAT OCCURRED IN JUNE 2023 IN A TIMELY OR PROPER MANNER. Status: Final Sanction Detail: THE FINE NOTICE IMPOSED A FINE ON DBAG OF EUR 50,000, WHICH IS APPROXIMATELY USD $54,081, WHICH WILL BE TIMELY PAID. Summary: ON FEBRUARY 8, 2024, BAFIN ISSUED A FINE NOTICE TO DBAG, FINDING THAT DBAG FAILED TO INFORM BAFIN OF AN INFORMATION TECHNOLOGY SECURITY INCIDENT THAT OCCURRED IN JUNE 2023 IN A TIMELY OR PROPER MANNER. THE FINE NOTICE IMPOSED A FINE ON DBAG OF EUR 50,000, WHICH IS APPROXIMATELY USD $54,081, WHICH WILL BE TIMELY PAID.

Allegations: ON JUNE 20, 2018, THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ("DFS"), DBAG AND DBAG'S NEW YORK BRANCH (COLLECTIVELY, "THE BANK") ENTERED INTO A CONSENT ORDER ("ORDER"). ALTHOUGH THE ORDER RECOGNIZED THE BANK'S "EXTRAORDINARY COOPERATION" WITH THE DFS AND INSTITUTION OF "WIDE-RANGING REFORMS TO ADDRESS IMPROPER CONDUCT IN ITS FX TRADING BUSINESS", THE DFS FOUND THAT THE BANK "FAIL[ED] TO IMPLEMENT EFFECTIVE CONTROLS OVER ITS FX BUSINESS" TO ENSURE THAT THE BANK'S FX ACTIVITIES COMPLIED WITH SAFE AND SOUND BANKING PRACTICES AND APPLICABLE INTERNAL POLICIES, WHICH PREVENTED THE BANK FROM DETECTING AND ADDRESSING IMPROPER CONDUCT BY CERTAIN OF ITS FX TRADERS AND SALESPERSONS FROM 2007 TO 2013. AS A RESULT OF THIS CONDUCT, THE DFS FOUND THAT THE BANK ENGAGED IN UNSAFE, UNSOUND, AND IMPROPER CONDUCT. Status: Final Sanction Detail: THE ORDER REQUIRED THE BANK TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $205,000,000, WHICH THE BANK PAID ON JUNE 22, 2018. Summary: THE BANK CONSENTED TO THE ENTRY OF THE ORDER ON JUNE 20, 2018 BY THE DFS, PURSUANT TO WHICH THE BANK: (A) SHALL PAY A CIVIL MONETARY PENALTY OF $205,000,000, WHICH THE BANK PAID ON JUNE 22, 2018; (B) SHALL NOT REHIRE OR RETAIN CERTAIN FORMER EMPLOYEES INVOLVED IN THE MISCONDUCT DESCRIBED IN THE ORDER; (C) SHALL SUBMIT WRITTEN PLANS TO IMPROVE SENIOR MANAGEMENT OVERSIGHT AND THE COMPLIANCE RISK MANAGEMENT PROGRAM, AN ENHANCED WRITTEN INTERNAL CONTROLS AND COMPLIANCE PROGRAM, AND AN ENHANCED WRITTEN INTERNAL AUDIT PROGRAM TO THE DFS WITHIN 90 DAYS OF THE ORDER; (D) FOR SUB-SECTION C, SHALL PROMPTLY IMPLEMENT THE APPROVED PLANS AND PROGRAMS WITHIN 10 DAYS OF APPROVAL BY THE DFS AND THEREAFTER FULLY COMPLY WITH THEM; AND (E) SHALL SUBMIT WRITTEN PROGRESS REPORTS TO THE DFS AT THE POINT OF 12 AND 24 MONTHS AFTER EXECUTION OF THE ORDER.

Allegations: THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") FOUND THAT, FROM AT LEAST JANUARY 2018 TO SEPTEMBER 2022, DBAG AND DBSI EMPLOYEES SENT AND RECEIVED OFF-CHANNEL COMMUNICATIONS THAT RELATED TO THE BUSINESS OF SWAP DEALERS AND FUTURES COMMISSION MERCHANTS, AND THAT DBAG AND DBSI DID NOT MAINTAIN OR PRESERVE THESE WRITTEN COMMUNICATIONS, RESULTING IN VIOLATIONS OF THE REQUIREMENTS TO PRESERVE CERTAIN BUSINESS-RELATED COMMUNICATIONS IN THE COMMODITY EXCHANGE ACT (THE "CEA"), AND THAT DBAG AND DBSI FAILED TO DILIGENTLY SUPERVISE THEIR EMPLOYEES IN RELATION TO THESE REQUIREMENTS. Status: Final Sanction Detail: DBSI WAS ORDERED TO CEASE AND DESIST FROM VIOLATING SECTION 4G OF THE CEA AND REGULATIONS 1.31, 1.35, AND 166.3 THEREUNDER; TO PAY, JOINTLY AND SEVERALLY WITH DBAG, A CIVIL MONETARY PENALTY IN THE AMOUNT OF $75,000,000, WHICH WAS TIMELY PAID ON OCTOBER 7, 2022; AND TO COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER. DBSI AND DBAG WILL CONDUCT A REVIEW TO ASSESS THEIR PROGRESS IN THE AREAS DESCRIBED IN THE ORDER. AFTER COMPLETION OF THIS REVIEW, DBSI AND DBAG SHALL ENSURE IT SUBMITS A REPORT TO THE COMMISSION STAFF. FOR TWO YEARS FOLLOWING THE ENTRY OF THE ORDER, DBSI AND DBAG SHALL NOTIFY THE COMMISSION STAFF UPON THE IMPOSITION OF ANY DISCIPLINE THEY IMPOSE. DBSI AND DBAG SHALL PRESERVE, FOR A PERIOD OF NOT LESS THAN SIX (6) YEARS FROM THE END OF THE FISCAL YEAR LAST USED, THE FIRST TWO (2) YEARS IN AN EASILY ACCESSIBLE PLACE, ANY RECORD OF COMPLIANCE WITH UNDERTAKINGS. Summary: ON SEPTEMBER 27, 2022, DBAG AND DBSI ENTERED INTO A SETTLEMENT WITH THE CFTC, WHICH THE CFTC APPROVED IN ITS ORDER OF THE SAME DATE. THE ORDER FOUND THAT FROM AT LEAST JANUARY 2018 TO SEPTEMBER 2022, DBAG AND DBSI EMPLOYEES SENT AND RECEIVED OFF-CHANNEL COMMUNICATIONS THAT RELATED TO THE BUSINESS OF SWAP DEALERS AND FUTURES COMMISSION MERCHANTS, AND THAT DBAG AND DBSI DID NOT MAINTAIN OR PRESERVE THESE WRITTEN COMMUNICATIONS, RESULTING IN VIOLATIONS OF THE REQUIREMENTS TO PRESERVE CERTAIN BUSINESS-RELATED COMMUNICATIONS IN THE CEA, AND THAT DBAG AND DBSI FAILED TO DILIGENTLY SUPERVISE THEIR EMPLOYEES IN RELATION TO THESE REQUIREMENTS. DBAG AND DBSI AGREED TO A FINE OF $75,000,000, WHICH WAS TIMELY PAID ON OCTOBER 7, 2022, AND TO RETAIN A COMPLIANCE CONSULTANT AND ADOPT THE COMPLIANCE CONSULTANT'S RECOMMENDATIONS RELATED TO THE PRESERVATION OF BUSINESS-RELATED COMMUNICATIONS.

Allegations: THE SECURITIES EXCHANGE COMMISSION ("SEC") FOUND THAT, FROM AT LEAST JANUARY 2018 TO SEPTEMBER 2021, DBSI, DDI AND DIMA EMPLOYEES SENT AND RECEIVED OFF-CHANNEL COMMUNICATIONS THAT RELATED TO THE BUSINESS OF BROKER-DEALERS AND INVESTMENT ADVISERS, AND THAT DBSI, DDI AND DIMA DID NOT MAINTAIN OR PRESERVE THE SUBSTANTIAL MAJORITY OF THESE WRITTEN COMMUNICATIONS, RESULTING IN VIOLATIONS OF THE REQUIREMENTS TO PRESERVE CERTAIN BUSINESS-RELATED COMMUNICATIONS IN THE SECURITIES EXCHANGE ACT OF 1934 (THE "EXCHANGE ACT") AND THE INVESTMENT ADVISERS ACT OF 1940 (THE"ADVISERS ACT"), AND THAT DBSI, DDI AND DIMA FAILED TO REASONABLY SUPERVISE THEIR EMPLOYEES IN RELATION TO THESE REQUIREMENTS. Status: Final Sanction Detail: DBSI, DDI AND DIMA WERE CENSURED; ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER; ORDERED TO PAY A CIVIL MONEY PENALTY, JOINTLY AND SEVERALLY, IN THE AMOUNT OF $125,000,000, WHICH WAS TIMELY PAID ON OCTOBER 7, 2022; AND ORDERED TO COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER. IN ADDITION, DBSI, DDI AND DIMA WERE REQUIRED TO RETAIN A COMPLIANCE CONSULTANT PURSUANT TO THE TERMS OF THE ORDER. FOR TWO YEARS FOLLOWING THE ENTRY OF THE ORDER, DBSI, DDI AND DIMA SHALL NOTIFY THE COMMISSION STAFF UPON THE IMPOSITION OF ANY DISCIPLINE THEY IMPOSE. IN ADDITION TO THE COMPLIANCE CONSULTANT'S REVIEW AND REPORT, DBSI, DDI AND DIMA WILL ALSO HAVE THEIR INTERNAL AUDIT FUNCTION CONDUCT A SEPARATE AUDIT(S) TO ASSESS THEIR PROGRESS IN THE AREAS DESCRIBED IN THE ORDER. AFTER COMPLETION OF THIS AUDIT(S), DBSI, DDI AND DIMA SHALL ENSURE THAT INTERNAL AUDIT SUBMITS A REPORT TO THE COMMISSION STAFF. DBSI, DDI AND DIMA SHALL PRESERVE, FOR A PERIOD OF NOT LESS THAN SIX (6) YEARS FROM THE END OF THE FISCAL YEAR LAST USED, THE FIRST TWO (2) YEARS IN AN EASILY ACCESSIBLE PLACE, ANY RECORD OF COMPLIANCE WITH THE UNDERTAKINGS. Summary: ON SEPTEMBER 27, 2022, DBSI, DDI AND DIMA ENTERED INTO A SETTLEMENT WITH THE SEC, WHICH THE SEC APPROVED IN ITS ORDER OF THE SAME DATE. THE ORDER FOUND THAT, FROM AT LEAST JANUARY 2018 TO SEPTEMBER 2021, DBSI, DDI AND DIMA EMPLOYEES SENT AND RECEIVED OFF-CHANNEL COMMUNICATIONS THAT RELATED TO THE BUSINESS OF BROKER-DEALERS AND INVESTMENT ADVISERS, AND THAT DBSI, DDI AND DIMA DID NOT MAINTAIN OR PRESERVE THE SUBSTANTIAL MAJORITY OF THESE WRITTEN COMMUNICATIONS, RESULTING IN VIOLATIONS OF THE REQUIREMENTS TO PRESERVE CERTAIN BUSINESS-RELATED COMMUNICATIONS IN THE EXCHANGE ACT AND THE ADVISERS ACT, AND THAT DBSI, DDI AND DIMA FAILED TO REASONABLY SUPERVISE THEIR EMPLOYEES IN RELATION TO THESE REQUIREMENTS. DBSI, DDI AND DIMA AGREED TO A FINE OF $125,000,000,WHICH WAS TIMELY PAID ON OCTOBER 7, 2022, AND TO RETAIN A COMPLIANCE CONSULTANT AND ADOPT THE COMPLIANCE CONSULTANT'S RECOMMENDATIONS RELATED TO THE PRESERVATION OF BUSINESS-RELATED COMMUNICATIONS.

Allegations: CFTC ALLEGED THAT DBAG FAILED TO PROPERLY REPORT CANCELLATIONS OF SWAP TRANSACTIONS IN ALL ASSET CLASSES, WHICH IN THE AGGREGATE INCLUDED BETWEEN TENS OF THOUSANDS AND HUNDREDS OF THOUSANDS OF REPORTING VIOLATIONS AND ERRORS AND OMISSIONS IN ITS SWAP REPORTING. CFTC ALLEGED THAT DBAG WAS AWARE OF PROBLEMS RELATING TO ITS CANCELLATION MESSAGES SINCE ITS REPORTING OBLIGATIONS BEGAN ON DECEMBER 31, 2012, BUT FAILED TO PROVIDE TIMELY NOTICE TO ITS SDR AND DID NOT DILIGENTLY INVESTIGATE, ADDRESS AND REMEDIATE THE PROBLEMS UNTIL IT WAS NOTIFIED BY THE DIVISION OF ENFORCEMENT'S INVESTIGATION IN JUNE 2014. CFTC ALLEGED THAT, BECAUSE OF DBAG'S REPORTING FAILURES, MISINFORMATION WAS DISSEMINATED TO THE MARKET THROUGH THE REAL TIME PUBLIC TAPE AND TO THE CFTC. CFTC ALLEGED THAT DBAG'S REPORTING FAILURES RESULTED IN PART DUE TO DEFICIENCIES WITH ITS SWAPS SUPERVISORY SYSTEM. CFTC ALLEGED THAT DBAG DID NOT HAVE AN ADEQUATE SYSTEM TO SUPERVISE ALL ACTIVITIES RELATED TO COMPLIANCE WITH THE SWAPS REPORTING REQUIREMENTS UNTIL AT LEAST SOMETIME BETWEEN APRIL AND JULY OF 2014. Status: Final Sanction Detail: DBAG AGREED TO PAY A $2.5 MILLION CIVIL MONETARY PENALTY AND COMPLY WITH UNDERTAKINGS TO IMPROVE ITS INTERNAL CONTROLS TO ENSURE THE ACCURACY AND INTEGRITY OF ITS SWAPS REPORTING. THE FINE WAS PAID ON OCTOBER 5, 2015. Summary: DBAG AGREED TO PAY A $2.5 MILLION CIVIL MONETARY PENALTY AND COMPLY WITH UNDERTAKINGS TO IMPROVE ITS INTERNAL CONTROLS TO ENSURE THE ACCURACY AND INTEGRITY OF ITS SWAPS REPORTING. THE FINE WAS PAID ON OCTOBER 5, 2015.

Allegations: THE SEC ALLEGED THAT DEUTSCHE BANK AG ("DBAG") IMPROPERLY USED THIRD-PARTY INTERMEDIARIES, BUSINESS DEVELOPMENT CONSULTANTS, AND FINDERS TO OBTAIN AND RETAIN GLOBAL BUSINESS FROM AT LEAST 2009 THROUGH 2016. THE SEC ALLEGED THAT DBAG LACKED SUFFICIENT INTERNAL ACCOUNTING CONTROLS RELATED TO THE USE AND PAYMENT OF BDCS DURING THE RELEVANT TIME PERIOD AND FAILED TO TAKE SUFFICIENT STEPS TO ADDRESS AND REMEDIATE KNOWN INTERNAL ACCOUNTING CONTROL FAILURES UNTIL 2016. THE SEC ALSO ALLEGED THAT PAYMENTS WERE INACCURATELY RECORDED AS LEGITIMATE BUSINESS EXPENSES IN DBAG'S BOOKS AND RECORDS, AND INVOLVED FALSIFIED INVOICES AND DOCUMENTATION. Status: Final Sanction Detail: DBAG AGREED TO CEASE AND DESIST FROM VIOLATING SECTIONS 13(B)(2)(A) AND 13(B)(2)(B) OF THE SECURITIES EXCHANGE ACT AND TO PAY DISGORGEMENT OF $35,145,619 AND PREJUDGMENT INTEREST OF $8,184,003, WHICH WAS TIMELY PAID ON JANUARY 14, 2021. Summary: ON JANUARY 8, 2021, THE SEC ENTERED AN ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING A CEASE-AND-DESIST ORDER (THE "ORDER") IN THE MATTER OF DEUTSCHE BANK AG. THE ORDER REQUIRES DBAG TO CEASE AND DESIST FROM VIOLATING SECTIONS 13(B)(2)(A) AND 13(B)(2)(B) OF THE SECURITIES EXCHANGE ACT AND TO PAY DISGORGEMENT OF $35,145,619 AND PREJUDGMENT INTEREST OF $8,184,003, WHICH WAS TIMELY PAID ON JANUARY 14, 2021.

Allegations: ON MAY 26, 2015, THE U.S. SECURITIES AND EXCHANGE COMMISSION (SEC) ISSUED A CEASE AND DESIST ORDER IN A SETTLED ADMINISTRATIVE PROCEEDING AGAINST DEUTSCHE BANK AG. THE MATTER RELATED TO THE MANNER IN WHICH DBAG VALUED "GAP RISK" ASSOCIATED WITH CERTAIN LEVERAGED SUPER SENIOR (LSS) SYNTHETIC CDO POSITIONS DURING Q4 2008 AND Q1 2009, WHICH WAS THE HEIGHT OF THE FINANCIAL CRISIS. GAP RISK IS THE RISK OF LOSS THAT CAN RESULT IF THE PRESENT VALUE OF A TRADE FALLS BELOW THE VALUE OF COLLATERAL FOR THE TRADE POSTED BY THE COUNTERPARTY. DURING THE TWO QUARTERS AT ISSUE, DBAG DID NOT ADJUST ITS VALUE OF THE LSS TRADES TO ACCOUNT FOR GAP RISK, ESSENTIALLY ASSIGNING A ZERO VALUE FOR GAP RISK. THE SEC FOUND THAT ALTHOUGH THERE WAS NO STANDARD INDUSTRY MODEL TO VALUE GAP RISK AND THE VALUATION OF THESE INSTRUMENTS WAS COMPLEX, DBAG DID NOT REASONABLY ADJUST THE VALUE OF THE LSS TRADES FOR GAP RISK DURING THESE PERIODS, RESULTING IN MISSTATEMENTS OF ITS FINANCIAL STATEMENTS FOR THE TWO QUARTERS AT ISSUE. THE SEC ALSO FOUND THAT DBAG FAILED TO MAINTAIN ADEQUATE SYSTEMS AND CONTROLS OVER THE VALUATION PROCESS. THE SEC FOUND VIOLATIONS OF SECTION 13(A) (REQUIREMENT TO FILE ACCURATE PERIODIC REPORTS WITH THE SEC), 13(B)(2)(A) (REQUIREMENT TO MAINTAIN ACCURATE BOOKS AND RECORDS), AND 13(B)(2)(B)(REQUIREMENT TO MAINTAIN REASONABLE INTERNAL ACCOUNTING CONTROLS). DBAG PAID A $55MN PENALTY AND NEITHER ADMITTED NOR DENIED THE FINDINGS. Status: Final Sanction Detail: DBAG WAS ORDERED TO PAY A FINE OF $55,000,000.00. THE FINE WAS PAID ON 6/9/2015. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBAG AGREED TO PAY THE FINE OF $55,000,000.00 WHICH WAS PAID ON 6/9/2015.

Allegations: THE SEC FOUND THAT DWS INVESTMENT MANAGEMENT AMERICAS, INC. ("DIMA") CAUSED THE U.S. REGISTERED MUTUAL FUNDS IT ADVISED TO FAIL TO DEVELOP AND IMPLEMENT A REASONABLY DESIGNED ANTI-MONEY LAUNDERING ("AML") PROGRAM TO COMPLY WITH THE REQUIREMENTS OF MUTUAL FUNDS UNDER THE BANK SECRECY ACT, AND APPLICABLE REGULATIONS PROMULGATED BY THE FINANCIAL CRIMES ENFORCEMENT NETWORK, AND THAT, FROM AT LEAST JANUARY 2017 UNTIL DECEMBER 2021, THE MUTUAL FUNDS INSTEAD RELIED UPON THE AML PROGRAM DESIGNED FOR THE U.S. OPERATIONS OF DEUTSCHE BANK AG, WHICH DID NOT ADDRESS THE SPECIFIC AML COMPLIANCE REQUIREMENTS FOR THE MUTUAL FUND BUSINESS. Status: Final Sanction Detail: DIMA WAS (I) ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF RULE 38A-1 UNDER THE INVESTMENT COMPANY ACT OF 1940 (THE "INVESTMENT COMPANY ACT") AND (II) ORDERED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $6,000,000, WHICH WILL BE TIMELY PAID. Summary: ON SEPTEMBER 25, 2023, WITHOUT ADMITTING OR DENYING THE FINDINGS THEREIN, DIMA ENTERED INTO A SETTLEMENT WITH THE SEC FINDING THAT DIMA CAUSED THE U.S. REGISTERED MUTUAL FUNDS IT ADVISED TO FAIL TO DEVELOP AND IMPLEMENT A REASONABLY DESIGNED AML PROGRAM TO COMPLY WITH THE REQUIREMENTS OF MUTUAL FUNDS UNDER THE BANK SECRECY ACT, AND APPLICABLE REGULATIONS PROMULGATED BY THE FINANCIAL CRIMES ENFORCEMENT NETWORK, AND THAT, FROM AT LEAST JANUARY 2017 UNTIL DECEMBER 2021, THE MUTUAL FUNDS INSTEAD RELIED UPON THE AML PROGRAM DESIGNED FOR THE U.S. OPERATIONS OF DEUTSCHE BANK AG, WHICH DID NOT ADDRESS THE SPECIFIC AML COMPLIANCE REQUIREMENTS FOR THE MUTUAL FUND BUSINESS. DIMA WAS (I) ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF RULE 38A-1 UNDER THE INVESTMENT COMPANY ACT AND (II) ORDERED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $6,000,000, WHICH WILL BE TIMELY PAID.

Allegations: THE SEC FOUND THAT DWS INVESTMENT MANAGEMENT AMERICAS, INC. ("DIMA") FAILED TO HAVE POLICIES AND PROCEDURES IN PLACE TO ENSURE ADEQUATE IMPLEMENTATION OF CERTAIN PROVISIONS OF ITS GLOBAL ESG INTEGRATION POLICY AS THEY PERTAIN TO CERTAIN OF DIMA'S ACTIVELY MANAGED MUTUAL FUNDS AND RETAIL SEPARATELY MANAGED ACCOUNT STRATEGIES. THE SEC FURTHER FOUND THAT BY VIRTUE OF DIMA'S FAILURES TO ADOPT AND IMPLEMENT REASONABLY DESIGNED POLICIES AND PROCEDURES TO ENSURE THE ACCURACY OF ITS PUBLIC STATEMENTS, CERTAIN OF ITS PUBLIC STATEMENTS ABOUT DIMA'S ESG INTEGRATION APPROACH CONTAINED MATERIAL MISSTATEMENTS. THE SEC DID NOT FIND THAT ANY OF THESE PUBLIC STATEMENTS WERE INTENTIONALLY FALSE. Status: Final Sanction Detail: DIMA WAS (I) CENSURED, (II) ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 (THE "ADVISERS ACT") AND RULES 206(4)-7 AND 206(4)-8 THEREUNDER, AND (III) ORDERED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $19,000,000, WHICH WILL BE TIMELY PAID. Summary: ON SEPTEMBER 25, 2023, WITHOUT ADMITTING OR DENYING THE FINDINGS THEREIN, DIMA ENTERED INTO A SETTLEMENT WITH THE SEC FINDING THAT DIMA FAILED TO HAVE POLICIES AND PROCEDURES IN PLACE TO ENSURE ADEQUATE IMPLEMENTATION OF CERTAIN PROVISIONS OF ITS GLOBAL ESG INTEGRATION POLICY AS THEY PERTAIN TO CERTAIN OF DIMA'S ACTIVELY MANAGED MUTUAL FUNDS AND RETAIL SEPARATELY MANAGED ACCOUNT STRATEGIES. THE SEC FURTHER FOUND THAT BY VIRTUE OF DIMA'S FAILURES TO ADOPT AND IMPLEMENT REASONABLY DESIGNED POLICIES AND PROCEDURES TO ENSURE THE ACCURACY OF ITS PUBLIC STATEMENTS, CERTAIN OF ITS PUBLIC STATEMENTS ABOUT DIMA'S ESG INTEGRATION APPROACH CONTAINED MATERIAL MISSTATEMENTS. THE SEC DID NOT FIND THAT ANY OF THESE PUBLIC STATEMENTS WERE INTENTIONALLY FALSE. DIMA WAS (I) CENSURED, (II) ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULES 206(4)-7 AND 206(4)-8 THEREUNDER, AND (III) ORDERED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $19,000,000, WHICH WILL BE TIMELY PAID.

Allegations: THE CFTC ALLEGED THAT DEUTSCHE BANK AG ("DBAG"), BY AND THROUGH THE ACTS OF CERTAIN PRECIOUS METALS TRADERS, MANIPULATED AND ATTEMPTED TO MANIPULATE PRICES AND ENGAGED IN SPOOFING IN THE PRECIOUS METALS FUTURES MARKETS ON VARIOUS OCCASIONS BETWEEN FEBRUARY 2008 AND SEPTEMBER 2014. THE CFTC ALLEGED THAT THESE TRADERS PLACED ORDERS TO BUY OR SELL FUTURES CONTRACTS WITH THE INTENT TO CANCEL THE ORDERS BEFORE EXECUTION, AND THAT SUCH ORDERS MANIPULATED AND WERE INTENDED TO MANIPULATE THE PRICES OF PRECIOUS METALS FUTURES CONTRACTS. THE CFTC ALLEGED THAT, THROUGH THE ACTS OF ONE TRADER, DBAG MANIPULATED THE PRICE OF PRECIOUS METALS FUTURES CONTRACTS AND TRIGGERED CUSTOMERS' STOP-LOSS ORDERS, ALLOWING THAT TRADER TO BUY PRECIOUS METALS FUTURES CONTRACTS AT ARTIFICIALLY LOW PRICES OR SELL SUCH CONTRACTS AT ARTIFICIALLY HIGH PRICES. THE CFTC ALSO ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") FAILED TO DILIGENTLY SUPERVISE IN CONNECTION WITH THE ABOVE REFERENCED CONDUCT. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBAG AND DBSI (TOGETHER "DEUTSCHE BANK") AGREED TO: (I) PAY A $30,000,000 CIVIL MONETARY PENALTY, ASSESSED JOINTLY AND SEVERALLY, WHICH WAS PAID ON FEBRUARY 2, 2018; (II) CEASE AND DESIST FROM VIOLATING CERTAIN PROVISIONS OF THE COMMODITY EXCHANGE ACT ("CEA") AND CFTC REGULATIONS RELATED TO MANIPULATION, SPOOFING, AND SUPERVISION; AND (III) COMPLY WITH UNDERTAKINGS REGARDING, AMONG OTHER THINGS, MAINTAINING SYSTEMS AND CONTROLS REASONABLY DESIGNED TO DETECT SPOOFING ACTIVITY, AND MAINTAINING TRAINING OF CERTAIN DEUTSCHE BANK EMPLOYEES ADDRESSING SPOOFING, MANIPULATION, AND ATTEMPTED MANIPULATION. Summary: ON JANUARY 29, 2018, DEUTSCHE BANK, WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS THEREIN, ENTERED INTO A SETTLEMENT WITH THE CFTC. THE CFTC APPROVED THE SETTLEMENT IN ITS ORDER INSTITUTING PROCEEDINGS PURSUANT TO SECTION 6(C) AND (D) OF THE COMMODITY EXCHANGE ACT, MAKING FINDINGS AND IMPOSING REMEDIAL SANCTIONS, INCLUDING THE FOLLOWING TERMS AND CONDITIONS. DEUTSCHE BANK AGREED TO PAY A $30,000,000 CIVIL MONETARY PENALTY, WHICH WAS PAID ON FEBRUARY 2, 2018; TO CEASE AND DESIST FROM VIOLATING CERTAIN PROVISIONS OF THE CEA AND CFTC REGULATIONS RELATED TO MANIPULATION, SPOOFING, AND SUPERVISION; AND TO COMPLY WITH UNDERTAKINGS REGARDING, AMONG OTHER THINGS, MAINTAINING SYSTEMS AND CONTROLS REASONABLY DESIGNED TO DETECT SPOOFING ACTIVITY, AND MAINTAINING TRAINING OF CERTAIN DEUTSCHE BANK EMPLOYEES ADDRESSING SPOOFING, MANIPULATION, AND ATTEMPTED MANIPULATION.

Allegations: DEUTSCHE BANK AG ("DBAG") AGREED TO SETTLE CHARGES OF MANIPULATION, ATTEMPTED MANIPULATION AND FALSE REPORTING RELATING TO USD, GBP, JPY AND CHF LIBOR AND EURIBOR. DBAG ALSO AGREED TO PAY A FINE OF $800 MILLION TO THE CFTC. DBAG ALSO AGREED TO COMPLY WITH CERTAIN UNDERTAKINGS RELATING TO BENCHMARK SUBMISSIONS. Status: Final Sanction Detail: DBAG WAS ORDERED TO PAY A FINE OF $800,000,000.00. THE FINE WAS PAID ON 5/1/15. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBAG AGREED TO PAY THE FINE OF $800,000,000.00 WHICH WAS PAID ON 5/1/15.

Allegations: THE SEC ALLEGED THAT DEUTSCHE BANK AG ("DBAG") PROVIDED EMPLOYMENT TO THE RELATIVES OF FOREIGN GOVERNMENT OFFICIALS AS A PERSONAL BENEFIT TO THOSE OFFICIALS IN ORDER TO INFLUENCE THEM TO ASSIST DBAG IN OBTAINING OR RETAINING BUSINESS OR OTHER BENEFITS BETWEEN 2006 AND 2014. THE SEC ALLEGED THAT DBAG'S 2010 ASIA-PACIFIC HIRING POLICY DID NOT APPLY TO ALL CATEGORIES OF HIRES AND WAS NOT EFFECTIVELY ENFORCED BY DBAG TO DETECT AND PREVENT ITS EMPLOYEES FROM OFFERING TEMPORARY EMPLOYMENT TO CANDIDATES REFERRED BY CURRENT OR POTENTIAL CLIENTS TO DETECT AND PREVENT CORRUPT HIRING PRACTICES. THE SEC ALLEGED THAT DBAG EMPLOYEES CREATED FALSE BOOKS AND RECORDS THAT CONCEALED THESE HIRING PRACTICES AND FAILED TO ACCURATELY DOCUMENT AND RECORD CERTAIN RELATED EXPENSES. THE SEC ALSO ALLEGED THAT DBAG FAILED TO DEVISE AND MAINTAIN A SYSTEM OF INTERNAL ACCOUNTING CONTROLS AROUND ITS HIRING PRACTICES SUFFICIENT TO PROVIDE REASONABLE ASSURANCES THAT ITS EMPLOYEES DID NOT VIOLATE ANTI-BRIBERY LAWS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBAG AGREED TO: (I) CEASE AND DESIST FROM VIOLATING SECTIONS 13(B)(2)(A) AND 13(B)(2)(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND (II) PAY DISGORGEMENT OF $10,785,900, PREJUDGMENT INTEREST OF $2,392,950, AND A CIVIL MONEY PENALTY OF $3,000,000, WHICH WAS PAID ON SEPTEMBER 3, 2019. Summary: ON AUGUST 22, 2019, DBAG, WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS THEREIN, ENTERED INTO A SETTLEMENT WITH THE SEC. THE SEC APPROVED THE SETTLEMENT IN ITS ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING A CEASE-AND-DESIST ORDER, INCLUDING THE FOLLOWING TERMS AND CONDITIONS. DBAG AGREED TO CEASE AND DESIST FROM VIOLATING SECTIONS 13(B)(2)(A) AND 13(B)(2)(B) OF THE EXCHANGE ACT AND TO PAY DISGORGEMENT OF $10,785,900, PREJUDGMENT INTEREST OF $2,392,950, AND A CIVIL MONEY PENALTY OF $3,000,000, WHICH WAS PAID ON SEPTEMBER 3, 2019.

Allegations: THE FRANKFURT STOCK EXCHANGE ("FSE") FOUND THAT, FROM NOVEMBER 2022 THROUGH DECEMBER 2022, DEUTSCHE BANK AG, FRANKFURT AM MAIN ("DB AG") FAILED TO CONVERT 339 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. Status: Final Sanction Detail: THE FSE CLOSED THE PROCEEDING WITHOUT ANY SANCTIONS, REQUIRED DB AG TO PAY A FEE FOR THE PROCEEDING OF EUR 1,000 (APPROXIMATELY USD 1,100), WHICH WILL BE TIMELY PAID. Summary: ON SEPTEMBER 2, 2024, DB AG RECEIVED A DECISION FROM FSE ISSUED ON JULY 13, 2024 FINDING THAT, FROM NOVEMBER 2022 THROUGH DECEMBER 2022, DB AG FAILED TO CONVERT 339 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. THE FSE CLOSED THE PROCEEDING WITHOUT ANY SANCTIONS, BUT REQUIRED DB AG TO PAY A FEE FOR THE PROCEEDING OF EUR 1,000 (APPROXIMATELY USD 1,100), WHICH WILL BE TIMELY PAID.

Allegations: THE FRANKFURT STOCK EXCHANGE ("FSE") FOUND THAT, FROM MARCH 2023 THROUGH APRIL 2023, DEUTSCHE BANK AG, FRANKFURT AM MAIN ("DB AG") FAILED TO CONVERT 353 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. Status: Final Sanction Detail: THE FSE CLOSED THE PROCEEDING WITHOUT ANY SANCTIONS, REQUIRED DB AG TO PAY A FEE FOR THE PROCEEDING OF EUR 1,000 (APPROXIMATELY USD 1,100), WHICH WILL BE TIMELY PAID. Summary: ON SEPTEMBER 2, 2024, DB AG RECEIVED A DECISION FROM FSE ISSUED ON JULY 12, 2024 FINDING THAT, FROM MARCH 2023 THROUGH APRIL 2023, DB AG FAILED TO CONVERT 353 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. THE FSE CLOSED THE PROCEEDING WITHOUT ANY SANCTIONS, BUT REQUIRED DB AG TO PAY A FEE FOR THE PROCEEDING OF EUR 1,000 (APPROXIMATELY USD 1,100), WHICH WILL BE TIMELY PAID.

Allegations: THE FRANKFURT STOCK EXCHANGE ("FSE") FOUND THAT, FROM SEPTEMBER 2023 THROUGH OCTOBER 2023, DEUTSCHE BANK AG, FRANKFURT AM MAIN ("DB AG") FAILED TO CONVERT 149 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. Status: Final Sanction Detail: THE FSE CLOSED THE PROCEEDING WITHOUT ANY SANCTIONS, REQUIRED DB AG TO PAY A FEE FOR THE PROCEEDING OF EUR 1,000 (APPROXIMATELY USD 1,100), WHICH WILL BE TIMELY PAID. Summary: ON SEPTEMBER 2, 2024, DB AG RECEIVED A DECISION FROM FSE ISSUED ON JULY 22, 2024 FINDING THAT, FROM SEPTEMBER 2023 THROUGH OCTOBER 2023, DB AG FAILED TO CONVERT 149 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. THE FSE CLOSED THE PROCEEDING WITHOUT ANY SANCTIONS, BUT REQUIRED DB AG TO PAY A FEE FOR THE PROCEEDING OF EUR 1,000 (APPROXIMATELY USD 1,100), WHICH WILL BE TIMELY PAID.

Allegations: THE FRANKFURT STOCK EXCHANGE ("FSE") FOUND THAT, FROM JANUARY 2023 THROUGH FEBRUARY 2023, DEUTSCHE BANK AG, FRANKFURT AM MAIN ("DB AG") FAILED TO CONVERT 389 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. Status: Final Sanction Detail: THE FSE CLOSED THE PROCEEDING WITHOUT ANY SANCTIONS, REQUIRED DB AG TO PAY A FEE FOR THE PROCEEDING OF EUR 1,000 (APPROXIMATELY USD 1,100), WHICH WILL BE TIMELY PAID. Summary: ON SEPTEMBER 2, 2024, DB AG RECEIVED A DECISION FROM FSE ISSUED ON JULY 9, 2024 FINDING THAT, FROM JANUARY 2023 THROUGH FEBRUARY 2023, DB AG FAILED TO CONVERT 389 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. THE FSE CLOSED THE PROCEEDING WITHOUT ANY SANCTIONS, BUT REQUIRED DB AG TO PAY A FEE FOR THE PROCEEDING OF EUR 1,000 (APPROXIMATELY USD 1,100), WHICH WILL BE TIMELY PAID.

Allegations: THE FRANKFURT STOCK EXCHANGE ("FSE") FOUND THAT, FROM JULY 2023 THROUGH AUGUST 2023, DEUTSCHE BANK AG, FRANKFURT AM MAIN ("DB AG") FAILED TO CONVERT 175 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. Status: Final Sanction Detail: THE FSE CLOSED THE PROCEEDING WITHOUT ANY SANCTIONS, REQUIRED DB AG TO PAY A FEE FOR THE PROCEEDING OF EUR 1,000 (APPROXIMATELY USD 1,100), WHICH WILL BE TIMELY PAID. Summary: ON SEPTEMBER 2, 2024, DB AG RECEIVED A DECISION FROM FSE ISSUED ON JULY 22, 2024 FINDING THAT, FROM JULY 2023 THROUGH AUGUST 2023, DB AG FAILED TO CONVERT 175 SHORT CODES INTO LONG CODES AS REQUIRED BY SECTION 114 OF THE FSE RULES, RESULTING IN A VIOLATION OF SECTION 26 G OF THE GERMAN STOCK EXCHANGE ACT AS WELL AS ARTICLE 25(2) AND (3) OF REGULATION (EU) NO. 600/2014. THE FSE CLOSED THE PROCEEDING WITHOUT ANY SANCTIONS, BUT REQUIRED DB AG TO PAY A FEE FOR THE PROCEEDING OF EUR 1,000 (APPROXIMATELY USD 1,100), WHICH WILL BE TIMELY PAID.