The BSA/AML Program encompasses Risk management requirements specifically related to BSA/AML compliance risks and includes the following core elements: BSA officer, policies, risk assessments, gap analyses, testing, training, data analytics, onmental Every employee has a role in managing risk at customer due diligence, sanctions screening, Wells Fargo. The company’s Risk Management transaction monitoring, reporting, other internal Envir Framework sets forth core principles for managing controls, and governing risk. Senior management sets the and independent audit. tone at the top by supporting a strong culture, 1 defined by the company’s expectations , that Global sanctions guides how employees conduct themselves and make decisions. The Board holds senior Wells Fargo has implemented a comprehensive Social management accountable for establishing and risk‐based sanctions compliance program maintaining this culture and for effectively designed to ensure compliance with applicable managing risk. economic sanctions laws and regulations in every jurisdiction in which it operates. Bank Secrecy Act and Anti-Money Laundering program Anti-bribery and corruption Wells Fargo’s risk-based global Bank Secrecy Act Wells Fargo has zero tolerance for bribery and ernance v and Anti-Money Laundering (BSA/AML) program corruption in any form. The Anti-Bribery and Go is designed to comply with applicable BSA/AML Corruption (ABC) program was reasonably designed laws commensurate with Wells Fargo’s risk profile. to comply with the U.S. Foreign Corrupt Practices The program is approved by Wells Fargo’s Board of Act, the United Kingdom Bribery Act 2010, and Directors through its Risk Committee. applicable ABC laws in the jurisdictions where Wells Fargo does business or seeks to do business. 1 Please see the Culture and Corporate governance and ethics 46 Environmental, Social, and Governance Report 2022 sections for more on the company’s expectations.