75 BSA/AML program Wells Fargo’s written BSA/AML compliance program is approved by the Wells Fargo’s Board of Directors (Board) and provides for the minimum requirements, known as the ‘Four Pillars’ of a BSA/ AML compliance program,1 as follows: 1. Corporate BSA Officer: As appointed and directed by the Board, the Corporate BSA Officer is responsible for administering and managing all aspects of the BSA/AML compliance program and for coordinating and monitoring Wells Fargo’s overall adherence to the BSA and its implementing regulations . 2. System of Internal Controls: As mandated by Wells Fargo’s size, structure, complexity, and risks, the BSA/AML Program maintains a strong system of internal controls, which includes a suite of preventive and detective controls designed to promote a strong compliance culture and manage risk transparently . Our financial crimes program includes maintaining corporate BSA/AML, Global Sanctions, and ABC policies; risk based customer due diligence, or know your customer, processes inclusive of higher risk categories such as cash intensive businesses and politically exposed persons; and monitoring, investigating, and reporting of suspicious activity . The scale of our business enables us to have significant impact through the products and services we offer our customers . With that comes the responsibility to acknowledge that business decisions made by Wells Fargo or our customers may have adverse impacts on people and the environment . To mitigate these impacts, we need to understand the inherent risk in our financing decisions, and we must work hard to detect, investigate, and report suspicious activity related to financial crimes and external fraud . Our Global Financial Crimes Risk Management Program and Environmental and Social Risk Management (ESRM) Framework help us navigate the evolving risk landscape associated with the potential impacts of our clients . Global financial crimes risk management Wells Fargo maintains a financial crimes program that is designed to assure compliance with applicable Bank Secrecy Act (BSA)/anti-money laundering (AML), counter-terrorist financing, global sanctions, and anti-bribery and corruption (ABC) related laws, regulations, and regulatory expectations, and to provide timely, actionable intelligence to appropriate authorities that may be indicative of financial crimes in order to safeguard the company, its employees, our customers, our communities, other stakeholders, and the global financial system . Understanding environmental and social impacts 1 . While different regulators consider CDD a fifth pillar, the Wells Fargo BSA/AML and Global Sanctions Compliance Program includes it in the internal controls pillar to be consistent with the Office of the Comptroller of the Currency view of the four pillars .