EFTA Document EFTA01362655

Tanu Kirti Director WM Mercury Implementation Programme Manager Tel. Mobi Em From: lain Macara Sent: 19 July 2018 11:13 To: Katherine Stead ; Aamir Akram Max Kleinert Cc: Clifford Fouri Oliver Bett ; Christopher Whyto Subject: RE: Family Office Initiative - Follow Up DJ Hi Katherine — thanks for including me. Tanushree 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 DB 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: i. 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 thanks From: Katherine Stead Sent: 19 July 2018 10:37 To: Aamir Akram Max Kleinert < Cc: Clifford Fourie ; Oliver Bettin Subject: Family Office Initiative - Follow Up [I] ain Macara Classification: For Internal use only Further to our call this morning, the following thoughts come to mind where we have a FO's being covered exclusively by KCP employees who are accessing GM systems: CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0052159 CONFIDENTIAL SDNY_GM_00198343 EFTA01362655