• 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. CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042402 CONFIDENTIAL SDNY_GM_00188586 EFTA01356512