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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 / proce

ligible clients, the CDD Form must be provided with all required KYC documentation during the KYC New Client Adoption process, as well as during the Regular Review process where form is not already on file, and during the Event Driven Review process. After the first account is opened using a newly obtained CDD

it Hi Adrienne: Yoonsun Chung oonsun Chung I hope all is well. Just a reminder to send us a listing of client names (or KYC #s) that were due for Regular Review at the end of January, February and March 2018. Thank you so much. Regards, Janice P. Franklin CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)

ligible clients, the CDD Form must be provided with all required KYC documentation during the KYC New Client Adoption process, as well as during the Regular Review process where form is not already on file, and during the Event Driven Review process. After the first account is opened using a newly obtained CDD