EFTA01415348.pdf

Sample 1: May MRC states the following NCAs for April: 8 high-risk NCAs; 20 moderate-risk NCAs; and 25 low-risk NCAs However, the NCA report during the walkthrough showed 9 high-risk NCAs: PEPs MRC slide 49 states 429 PEPs; however, during the walkthrough GA noted 431 PEPs: Sample 2: August MRC states the following NCAs for July: The data reported to MRC is: 8 high-risk NCAs; 4 moderate-risk NCAs; and 14 low-risk NCAs However, the NCA report run on March 9th by GA reflected: 7 High Risk NCAs 6 Moderate Risk NCAs; and 18 low-risk NCAs March 9, 2018 report: *Please note:* GA ran the report March 22, 2018 (10:59 AM) — sent via e-mail to WM AFC and noted the following: 7 high-risk NCAs; 7 moderate-risk NCAs; and 9 low-risk NCAs March 22, 2018 Report Sample 3: October MRC states the following NCAs for September: EFTA01415348 2 high-risk NCAs; 15 moderate-risk NCAs; and 14 low-risk NCAs However, the NCA report run on March 9th by GA reflected: 5 high-risk NCAs; 14 moderate-risk NCAs; and 14 low-risk NCAs (NO DISCREPANCY between info sent to MRC and source data) March 9, 2018 report: Sample 4: November MRC states the following NCAs for October: 3 high-risk NCAs; 14 moderate-risk NCAs; and 29 low-risk NCAs However, the NCA report run on March 9th by GA reflected: 2 high-risk NCAs; 13 moderate-risk NCAs; and 29 low-risk NCAs March 9, 2018 report: For Brokerage (slide 146) GA was unclear as to whether the "Key Risk Drivers for High Risk NCAs" and "August Key Risk Drivers for High risk NCAs" were intended to be duplicates. In previous month(s), the total were different in both charts. There is a discrepancy in the breakdown between the two charts. Neither population breakdown reconciles against the source report, PershingAccountsWithAmlRiskDesignation, which reflects - four (4), not three (3), key risk drivers, as follows: - A04 (locally / divisionally defined high risk countries), - B11 (healthcare and pharmaceutical), - B13 (locally / divisionally defined risk industries), - and CO2 (doubtful reputation/negative information). Further, one chart reflects a total of 5 NCAs across 3 key risk drivers, and the other chart reflects 9 NCAs across 3 risk drivers. However, per PershingAccountsWithAmlRiskDesignation report, there are only 3 NCAs. Please see below the Pershing report WM AFC provided to GA: EFTA01415349 Confidential Confidential Confidential EFTA01415350