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EFTA01356674 | EFTA01356674 Review of clients with increased likelihood of error of judgement vs. WM risk appetite Areas of Specific Review Clients flagged with negative media against them 2 3 Data Sources System based identification e.g. in US (TBD in other BCs) Bottom-up checks to validate the systembased info (i.e., from market heads and teams) Likely Population • All HR clients (globally -7K) • Some portion of MR / LR e.g. if 20% MR - II 2.3K if 10% LR -*3.9K Clients that went through escalation • CAF (Client Acceptance Forum) • WM RRAP (Rep Risk Assessment Process) • RRRC (Regional Rep Risk Committee) • Event Driven Reviews • BC files (few CAF cases) • WM DC0 Inventory • Historic inventory • TBD • TBD Clients that solely bank with WM ("last man standing?") • No system based info available • File specific searches • Suggested to use as overlay to 1 and 2 to prioritize Clients whose files contain certain key words • TBD re technical feasibility outside the US • Suggested to use as overlay to 1 and 2 to prioritize • Less than 100 cases Confidential CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) CONFIDENTIAL DB-SDNY-0042662 SDNY_GM_00188846 EFTA01356674
February 14, 2026 at 7:41 PM