EFTA Document EFTA01370077

subject I client is the UBO. 7 10/18/2017 Active Unable to locate a case. DbForce states "Legacy Risk Calculator Review". Unable to locate a case. DbForce states "Legacy Risk Calculator Review". Moderate WM - PB GA was unable to identify an EDR case raised after the SAR was filed. Additionally, this client remains at a moderate risk rating. 8 11/22/2017 Active 1830090 In Progress (created on 9/21/2017) High WM - PB GA identified a case "in progress" created on 9 /21/2017. (Two months before the SAR filing). • 49 clients with RR due dates greater than 1 year • 27 moderate risk clients with RR due dates greater than 2 years • 31 low risk clients with no RR due dates The all KYCS Risk Rating report was run from DbForce (PB). (Please refer to attachment: WM_all KYCS —1`r report-_ .xlsx) Finding #3 • direct owner (99.9%) not included in the ownership chain of the KYC profile • clients with PEP relationship not escalated to BLAFC — if different from comment listing under Findings #1 • clients with PCR/negative news not escalated to BLAFC for review Finding #4 9 Specific MI which GA was unable to reconcile/re-perform (Regarding discrepancy(s) noted across four month of MI reviewed.) GA had provided supporting documentation for this previously, but I have re-attached, with an updated screen shot regarding the discrepancy noted in PEP totals. (Please refer to attachment: Reporting & Statistics for WM AFC_sent on 04.25.18.docx) 1. For the month of April (reported in May) for Private Bank: a. GA reviewed the statistics provided in the MRC deck (page 45) and noted: 25 low-risk clients: 20 moderate-risk clients; and 8 high-risk clients. The statistics WM AFC provided the MI team totaled 8 high-risk clients. However, during the walkthrough, GA noted there were 9 high-risk clients on the NCA report from DbForce; not 8 as reflected in the MRC deck. b. GA reviewed the statistics in the MRC deck (page 45) and noted: 3 NCAs associated with high-risk jurisdiction: 7 NCAs associated with high-risk industry; 4 NCAs with doubtful / negative information; and 1 NCA treated as a PEP relationship. This results in a total of 15. The statistics WM AFC provided to the MI Team were the same, totaling 15. However, during the walkthrough, GA noted that there were 9 high-risk clients on the NCA report from DbForce; not 15 as reflected in the MRC deck. c. GA reviewed the statistics provided in the MRC deck (page 45) and noted, for April 2017: 429 total PEP clients. The statistics WM AFC provided to the MI Team were the same, totaling 429. However, during the walkthrough, GA noted 431 PEP clients as the total. CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0062674 CONFIDENTIAL SDNY_GM_00208858 EFTA01370077