EFTA Document EFTA01368874

From: Cherie Quigley Sent: 3/10/2015 4:02:37 PM To: Sharon DonagheyI Subject: RE: WM Data Analysis for AML Risk Assessment [I) Attachments: 2012.2013 all wires.xlsx; 2012-2013 internal transfers.xlsx; 2012.2013 Free Rec and Del.xlsx; 2012-2013 Free Rec and Del.xlk; 2012.2013 check deposits.xlsx; 2012.2013 IA accounts.xlsx Classification: For Internal use only Hi Sharon Here are the spreadsheets. Cherie From: Sharon Donaghey Sent: Thursday, March 05, 2015 3:18 PM To: Cherie Quigley; Ying-A Wang Cc: Wayne Salit Subject: WM Data Analysis for AML Risk Assessment [I] Classification: For internal use only Hi Cherie and Ying, I believe that Wayne spoke to you about gathering some metrics for the products in the WM Investment Advisory Business so that we can complete the AML Risk Assessment for 2014, which included data for 2012 and 2013. These are the products that were indicated as applicable in the Spring of 2014: • Check deposits • Free delivery/receipt of securities • Internal Transfers • Investment Advisory • Wire Transactions Attached is a worksheet that includes the tables for the metrics that we want to capture, i.e. the number of accounts, transaction volume and the total transaction value by client risk rating and by country risk. If possible, please also provide the metrics by client's high risk industry status, but not if this will be more time consuming. Data was collected last year and is available on the Risk Assessment Sharepoint site. (You may have other options for pulling the data. If that's the case, in order to be consistent with the other divisions, please provide metrics for 2012 and 2013.) Here's the link to the site: https://sharepoi nt.us.i ntranet.db.com/site2S10/Fall%202014%20AML%20Risk%20Assmt/Forms/AllItems.aspx?Root Fold er=%2Fsite2S10%2FFall%202014%20AML%20Risk%20Assmt%2FAWM%2FData%20Analysis%20n%200ther&FolderCTID =0x0120009280F9074DSAA142AC7BCAB4D1559F5D&View=f 7F9F3F7D-1490-40AE-BF00-4341EF424ASCI Clarissa used this data to generate metrics for last year's assessment, but it's not possible to get the metrics we need for this iteration of the assessment: data needed to generate the metrics by client and country risk needs to be mapped against the client data. If you have a few minutes, I'll further explain the challenge that I had with getting the metrics needed — it would be easier to show you in the worksheet. Regards, Sharon CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0060834 CONFIDENTIAL SDNY_GM_00207018 EFTA01368874