EFTA01372644

o If alerted, should it have been escalated to AML Compliance? • Enter findings from Monthly CAG File Review Assessment form onto the CAG Monthly Summary Review Excel Spread sheet o X in the named field if applicable ,present and correct o N/A in the named field if not applicable to that File o X In the name field if applicable, missing or incorrect o Add to comments field to explain issue • Upon Completion of CAG Monthly Summary Review Excel spread sheet o Tally all of the X and X in the data elements o Tally all of the X in the data elements o Calculate the percentage of X in the total data elements o Send E-mail to GM AML management and CAG/CRM management with findings and request for CAG to provide corrections for designated errors 106 1 CAG file review ninthly assessrrent • CAG resolution o CAG will send missing data elements or correct NAOP system elements within a timely manner o If elements cannot be corrected and deficiencies for a Base or Sub-account are extreme , Base or Sub-account must be closed immediately CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0066430 CONFIDENTIAL SDNY_GM_00212614 EFTA01372644