EFTA01356674.pdf

Review of clients with increased likelihood of error of judgement vs. WM risk appetite Areas of Specific Review Data Sources Likely Population Clients flagged with negative media against System based identification e.g. in US (TBD • All HR clients (globally -7K) them in other BCs) • Some portion of MR / LR Bottom-up checks to validate the system- e.g. if 20% MR - II 2.3K based info (i.e., from market heads and if 10% LR -*3.9K teams) 2 Clients that went through escalation • CAF (Client Acceptance Forum) • BC files (few CAF cases) • WM RRAP (Rep Risk Assessment Process) • WM DC0 Inventory • Less than 100 cases • RRRC (Regional Rep Risk Committee) • Historic inventory • Event Driven Reviews • TBD • TBD 3 Clients that solely bank with WM ("last man • No system based info available • Suggested to use as overlay to 1 and 2 to standing?") • File specific searches prioritize Clients whose files contain certain key words • TBD re technical feasibility outside the US • Suggested to use as overlay to 1 and 2 to prioritize Confidential CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042662 CONFIDENTIAL SDNY_GM_00188846 EFTA01356674