EFTA Document EFTA01362620

All, We took the attached list of WM clients to the ICG team to establish the most appropriate way to avoid trades for WM clients requiring ICG coverage from being blocked due to disconnect between CIB's central offboarding tracker and Tradefinder data. There was a preliminary discussion with lain Macara from ICG, who has agreed that for cases where WM ask ICG to execute trades, WM's order can be taken even if the GM status is Red, provided the Red/Amber cases in CIB are agreed to be Green centrally via the appointment of a WM ACO. Before we can take this list for approval, there are actions/ status for WM owners that I have highlighted in column U OF 'COMBINED WITH FILE ID' tab, mainly for Red/Amber cases: 1. For client without a GM business relationship in column H, note that they cannot be progressed as ICG do not deal with non GM client (if any non GM ones are red and you are concerned about it, it can be dealt via a 2018 full CIB population check we are commencing) 2. For green GM clients in column J — no action as CIB ACO is intact 3. For Reds and Amber GM clients in column J, we have checked with CIB and some items are for noting & some for action : For action: a. Not on 52k —WM ACO to provide approval to be the new ACO b. Not on 52k KYC out of date — WM to check if KYC is up to date and provide confirmation from ACO that record is up to date and ACO can take ownership For noting: a. On 52k but WM agreed to offboard — action to check why these are on the current list (all KCP US cases) b. On 52k but not identified as WM interest — action to check why these are on the current list (KCP US & EMEA cases) c. On 52k but too late to retain at the time of 52k check —1 case was not retained at the time and should not be on this list (APAC coverage— Reema's case) d. On dbKYCs remediation — these clients are currently being remediated so we have asked if any additional action is required (APAC coverage — Reema's cases) e. Retained as part of AFC dispensation —1 case has been retained recently — CIB will ensure the status is changed to green (EMEA KCP case) Can I please request you to make note of the noting items and progress your actions in the next week to have a confirmed view by mid August. If there are any immediate concerns, please go via Saleha or Sonya as I am out of office next week. Best, Tanu Tanu Kirti Director WM Mercury Implementation Programme Manager CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0052115 CONFIDENTIAL SDNY_GM_00198299 EFTA01362620