EFTA Document EFTA01356652

b) East Coast Business Manager - Armen Brash c) Investment Advisory - Mary Keaveney d) Fixed Income - Ron Colonna, James (Jim) Donofrio High Risk Media Policy Below attached is the High Risk Media Policy for Financial and Non-Financial 'transactions Snlittine Transaction • Transaction approvers must ensure that an instruction is not being split to avoid a control or policy requirement. • Prior to approving a transaction, TAG must check if any other transactions have been processed out of the same account that day. • If multiple transactions are located, then TAG must review the amount to see if they total more than $50K or more than $500MM. If not, then they can proceed with the usual process. • If the aggregate transactions exceeds $50K but is less than $500MM and being processed based on Verbal Instructions, without written authorization or a call back, then, TAG must check to see if the recipient of the funds is the same. • If the recipient is the same, then TAG must reject the transaction for Written Authorization from the client PLUS evidence of the call back. • If the recipient is NOT the same, then the transaction can be processed per the usual procedures. • If the aggregate transactions exceeds $500MM, then, TAG must check to see if the recipient of the funds is the same. • If the recipient is the same, then TAG must reject the transaction for the "Bear Trap" control (MD Release Approval Template). • If the recipient is NOT the same, then the transaction can be processed per the usual procedures. For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042619 CONFIDENTIAL SDNY_GM_00188803 EFTA01356652