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) a