EFTA01356557.pdf

2. Overview of remediation (to be completed by Finding Owner) Summary of remediation • Existing accounts: i. Determined EEA Customersfaccounts (excluding UK and Germany). d. Determined EEA accounts to be retained or exited (retain financials criteria: CBV>Eur2in or Annualized Rev>Eur20k). hi. Obtained reverse solicitation evidence (bankers attestation or EEA Client Declaration form) and reviewed with US compliance & DCO. iv. Exited/restriced EEA accounts not meeting financials criteria with the exception of 2 OPM accounts holding illiquid positions and for which management fees were removed. v. Obtained Mgmt exception approval to retain EEA accounts not meeting the financials criteria due to strong business rational to be retained. • New accounts: i. Implemented approval process for new EEA clients/accounts (EMEA legal & compliance approvals — see attached evidence for operational effectiveness). it Implemented reverse solicitation controls at the lead/prospect. account, and transaction levels. In Implemented and communicated process to Identify EEA clients to ABR/AFC (see attached evidence for operational effectiveness). • Implemented controls (checklist) for doimicle changes into the EEA and updated coverage and TAG Teams KOPs. • Rolled out training to impacted staff. • Drafted proposed controls for EEA designated bankers team to be implemented for EEA clients. Rationale for holistic vs localised approach (complete for F3-F4 seventy findings( Localised approach was taken to address reverse solicitation requirements in order to not require MIFID II implementation for EEA clients (excluding UK and Germany) serviced by WM US. Remediation Details °I key !homes identified as part of fho Finding and the a.sso3f0Ci fomodorloo approach Finding AreaiRisk statement(s) New/amended compensating control(s) & additional remedial activities Conlimi existing account scope Account. hake been identified through data quen and validated 1w Business Mws. who to. icv.ed with Accountabk Client Owners (ACOs) to confirm whether in 9cope for Flit (Ind.Joint. sect hoMer(s) or decision maker, Legal Entities: country of primary decision make (s)} Determine EEA accounts to be retained or exited Accounts meeting the "retain financials" criteria established by maul. were retained. (Rho-wise exited unless an exception to retain was approved by WM Americas COO. (retain financials critait CBV>Eur2m or Annualized Rev :-Eur20k). EEA retain accounts in:mediation (see atlachement Obtained reverse solicitation evidence (banker's attestation for further details) or FEA Client Deflaration form) and reviewed with US compliance & I)CO. EF:A exit accowititanediation (see anachement for Mailed exit letters to clients (2 letter) for accounts in scope. further details) Once transfer instructions were obtained from the client proceeded with closure or account restrictions (where possible). 2 OF.NI accounts remained open as they hold illiquid positions and for which managartent fees were removed. EEA exit accounts exceptions to retain Obtained NIgml approval and obtained reverse solicitation evidence for EEA accounts not meeting the financials criteria but with strong business rational to he pained (e.g, future growth opportunities} Training Training was conducted in September 2018 to impacted staff. Process to detemtine EEA customers Required steps have been outlined and communicated to For infomal use only Page 5 or 12 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042464 CONFIDENTIAL SDNY_GM_00188648 EFTA01356557