EFTA Document EFTA01362641

Yes, we are currently working with our KCP teams to pull together the list of WM clients where we are dependent on ICG to place orders. This list as agreed with you will be taken within CIB management to get approval for ICG to take orders even if the GM status is red in tradefinder. We will get back to you with the list as soon as we have the reviewed data. Best, Tanu Tanu Kirti Director WM Mercury Implementation Programme Manager Tel. Mobi From: lain Macara Sent: 19 July 2018 11:13 To: Katherine Stead Aamir Akram ax Kleinert Cc: Clifford Fourie ; Oliver Bettin Christopher Whyto Subject: RE: Family Office Initiative - Follow Up [I] Hi Katherine — thanks for including me. anushree Kirti There's been a lot a dialogue with Wealth on the ACO subject this last week or 2 with Tanushree on point for Wealth (cc'ed). The approach we agreed with regard to WM clients needing GM product coverage is summarised below: • Wealth will define a client perimeter with the central Mercury programme and assign ACOs to all those clients (including KCP) • If ICG has it's own relationship with the client as well, then ICG will also have an ACO and the client would be green in the ICG perimeter • If ICG does not have it's own relationship with the client, then the client would remain red in ICG - (importantly this does not mean the GM infrastructure will be closed as of course the GM business relationship remains green at the D8 level by virtue of having an eligible ACO allocated) • Where ICG input is required on client that are red in ICG, we are looking to Stefan/Louise approve that: ICG people are allowed to take orders from Wealth people; and ii. we will continue to have no ACO for the client and therefore Wealth will own the KYC entirely • Believe Tanushree and team are working on the list? • (To facilitate Katherine, we'd look to deploy a new flag in TF etc telling our guys they won't get dinged on these clients) Shout with qs CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0052139 CONFIDENTIAL SDNY_GM_00198323 EFTA01362641