s for High Risk NCAs" & September Key Risk Drivers for High Risk NCAs do not include September 2017 totals. As such, GA did a comparison of metrics WM AFC provided to the MI team for September. GA noted the following numbers WM AFC provided to the MI team: 14 low-risk, 15 moderate risk, and 2 high risk

include September 2017 totals. As such, GA did a comparison of metrics WM AFC provided to the MI team for September. GA noted the following numbers WM AFC provided to the MI team: 14 low-risk, 15 moderate risk, and 2 high risk. However, the NCA report GA ran showed as follows: 5 high-risk NCAs, not 2

his pattern of cashing checks gives the appearance of structuring to avoid CTRReporting. WM AFC explained the concept of structuring to the client. WM AFC made it clear that they were not mandating that he change the manner in which he chooses to conduct his business or how he should cash his checks, b

ribed above and in the prior SARs. Indyke was informed that his pattern of cashing checks gives the appearance of structuring to avoid CTRReporting. WM AFC explained the concept of structuring to the client. WM AFC made it clear that they were not mandating that he change the manner in which he chooses

sk NCAs March 9, 2018 report: a' NCA Qtrly Report July2017.xlsx "Please note:" GA ran the report March 22, 2018 (10:59 AM) — sent via e-mail to WM AFC and noted the following: Confidential CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0063969 CONFIDENTIAL SDNY_GM_00210153 EFTA013708

CAs across 3 risk drivers. However, per PershingAccountsWithAmlRiskDesignation report, there are only 3 NCAs. Please see below the Pershing report WM AFC provided to GA: PershingAccounts WithAmIRiskDesign. Confidential CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0063971 CONFIDENTIAL

his pattern of cashing checks gives the appearance of structuring to avoid CTR Reporting. WM AFC explained the concept of structuring to the client. WM AFC made it clear that they were not mandating that he change the manner in which he chooses to conduct his business or how he should cash his checks, b

k Ranking and KYC due date synchronization a. obtain GM's risk ranking for all impacted clients b. compare to WM's risk ranking c. discuss with WM AFC to match GM's risk to WM's risk so these clients are on the same KYC cycle 4. All — discuss tracking IWP's "Market Professionals" in DBforce Ori

e Ian — Risk Ranking and KYC due date synchronization obtain GM's risk ranking for all impacted clients compare to WM's risk ranking discuss with WM AFC to match GM's risk to WM's risk so these clients are on the same KYC cycle All — discuss tracking IWP's "Market Professionals" in DBforce EFTA0139

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 Db