Negative media in context of other lifecycte controls New Client Adoption Source of Wealth Event Driven Review I 1 I\N \ Transaction Account Behavior Negative Media Source of Funds Monitoring (via RM, no Tools) Alerts Regular Review Inherently biggest area of judgment • Real allegations? • Completeness of allegation? • Politically motivated allegations? • Allegations / proceedings but no conviction yet? / ever? • How much/what negative news is still within risk appetite? Name List Screening / Sanctions alerts Confidential CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042663 CONFIDENTIAL SDNY_GM_00188847 EFTA01356675