EFTA01356674

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