UKGI00002196 - Email from Alwen Lyons to Alice Perkins, Neil McCausland, Virginia Holmes and others re: Update after February Board - various attachments in email header including Prosecutions Policy Reactive Briefing 25/02/2014 v2

Evidence on official site

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Subject: Update after February Board

Attachment: 2014 01 27 FS Sub committee minutes draft final.doc

Attachment: 20140226 Business Transformation_Board_Brief vO 4 Final.ppt

Attachment: 140218 POL Offshoring Report v2.pptx

Attachment: Risk Note - AML and Sanctions Final.docx

Attachment: board - public purpose.doc

Attachment: Prosecutions Policy Reactive Briefing 25 02 14 V2 (2).doc
Dear All

There were questions on several topics at the Board meeting which the presenters thought would be helpful to
provide updates to sooner rather than later:

Business Transformation — the papers handed out at the meeting are attached and we have also added to the Reading
room on the ipad, in the folder ‘Follow up from Board Meeting 26 February 2014’

FS Sub Committee — the draft minutes of the FS Sub Committee are attached for your information

Moneygram — Legal opinion on dealing with a US corporate handling overseas payments , and any possible recourse
back to the Post Office

In summary:

* Regulatory liability sits with Moneygram as the money the transmitter, not the Post Office;

* The Post Office obligation is to comply with the procedures as laid down by Moneygram and, as long as it
does so, benefits from indemnities etc;

* Director liability can only be crystallised once corporate liability is established, which would require
deliberate action by Post Office individuals on behalf of the company to commit an offence;

* For the liability to pass to the Board would require one or more directors to consent, connive or be negligent
in their duties in such a way as to allow an offence to be committed;

* Moneygram have been subject to sanction in the US but this has had no material impact on the Post Office
business as far as can be determined;

* Attached document contains the detailed analysis from DAC Beachcroft.

Public Purpose Statement — attached is the Board response to ‘why’ the Post Office exists
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Prosecutions Policy Reactive Briefing - attached is amended briefing from Mark, which he says has not had legal input
yet and would like it read in that light.

Thanks
Alwen
Alwen Lyons I Company Secretary

@® 148 Old Street, LONDON, EC1V 9HQ

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