EFTA01356567

4. Escalation process: a. If no evidence or no explanation is found in the call note escalate per the following: i. Send email to business managers (Table below) with the following: "It was detected a significant inflow for an EEA account was executed. I reviewed the cross border call notes and could not find any reverse solicitation explanation. Please follow up with banker where reverse solicitation was documented and revert back" Business Manager Escalation Table: Business Manager Name Business Armen Brash US Onshore Armen Brash/Janet Morales Latam Sylvia Junghardt GAT ii. Ensure that reverse solicitation documentation is in dbForce for all large inflows b. Document all escalations with comments in the BSO column For internal use only 3/2019 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042479 CONFIDENTIAL SDNY_GM_00188663 EFTA01356567