Negative media in context of other lifecycte controls
Event Driven
New Client Review Regular Review
Adoption
I
1
I\N \
Source of Wealth Transaction Account Behavior Negative Media Name List Screening /
Source of Funds Monitoring (via RM, no Tools) Alerts Sanctions alerts
Inherently biggest area of judgment
• Real allegations?
• Completeness of allegation?
• Politically motivated allegations?
• Allegations / proceedings but no conviction yet? / ever?
• How much/what negative news is still within risk appetite?
Confidential
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042663
CONFIDENTIAL SDNY_GM_00188847
EFTA01356675