EFTA Document EFTA01399047

Subject: Managed Exit account handling From: Oliver Esslingen Date: Thu, 30 May 2019 11:36:52 -0400 To: Ian Salters e, Funda Bozkurt Bill King Kimberly Hart S, Janice Franklin Maria Pedulla Term Definition PA Checks/Review Review of client account activity to establish open obligations which prevent offboard Managed Exit A process state for client entities identified for offboarding but have open obligations which prevent process completion Notification The process of sending a client notification to terminate the contractual relationship at the end of a defined notice period In Closure The process of closing DB transactional system accounts representing the impacted client entity Offboarded A count of client entities which have completed all offboarding process stages, and are inactivated through to KYC Records - classified as 'Full' Offboard when evidenced, complete removal of client entity from all businesses & jurisdictions inclusive of all tech platforms. Applied to all DB adoption entities globally. Below is how the CIB process works: The client is marked to be Off-Boarded but cannot be as there is an outstanding obligation (i.e. loan or position) with the client Client has been deemed to be KYC relevant by Business Managed Exit team searches in paid/public sources for the 4 below attributes Proof of Existence Legal Representatives Ownership/IBO Identity (ID)/Nationality & Source of Wealth (SOW) (Net Worth & source from where it is acquired) If not found, 2 notification letters are dispatched to the client seeking information Business is not involved in the sourcing of data EFTA01399047 Case is enriched KYC is collected on a best effort basis and if all 4 attributes cannot be sourced it is notated in the file Account will be quarantined until the obligation/position expires ACO signs off on the Managed Exit If High Risk, case is escalated to AFC for approval After obligation/position expires, client will be Off-Boarded The process will continue as per the Risk Rating (1 year -- High, 2 years — Medium, 5 — Low) until the position expires. Please let me know if you have any questions. EFTA01399048