EFTA01356569

3. If a customer is deemed as EEA customer, ABR/AFC will update the 'EEA Client Type" field of the customer profile by selecting "Retail", and the EEA Country field should be updated accordingly. 4. Scenarios for AFC and ABR to reach out to the FO/CM for KYCs where Primary Decision Maker has not been designated: # 1 Acct Type Individual/Joint Scenario o POA FO reach out Yes/No? No Conclusion Account holder is Primary Decision Maker and does not need to be designated. 2 Individual/Joint With POA(s) Yes Primary Decision Maker should be designated. 3 Entity One POA listed No POA is Primary Decision Maker and should be designated. 4 Entity Multiple POA listed Yes Primary Decision Maker should be designated. Primary Decision Maker" is defined as the person responsible for making decisions on behalf of the client on the particular account. If a Primary Decision Maker residing in an EEA country is designated on any of the account holder's accounts, the account holder will be subject to EEA restrictions on all of its accounts. EEA country list: Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom, Iceland, Liechtenstein and Norway. For internal use only CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0042481 CONFIDENTIAL SDNY_GM_00188665 EFTA01356569