demos.mrccsolutions.com · Web viewBNP Paribas. Introduction Storyboard. State Street. Ongoing Customer Relationship Storyboard . State Street

State Street

Ongoing Customer Relationship Storyboard

State Street

Ongoing Customer Relationship

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State Street


DOCUMENT HISTORY

Created/Revised By

Revision Details Created/Revised on

Version No

Priya Tiwari Initial Draft December 11, 2014 0.1Vikas Salgaonkar Client Feedback

ImplementationDecember 22, 2014 1.0

Shweta Mukherjee Added the interaction on screen 4

December 29, 2014 1.1

Priya Tiwari ID review changes December 30, 2014 1.2Priya Tiwari Client Feedback

ImplementationDecember 31, 2014 1.3

Vikas Salgaonkar Client Feedback Implementation

January 02, 2014 1.4

Shweta Mukherjee Client Feedback Implementation

January 6, 2015 1.5

Shweta Mukherjee ID review January 7, 2015 1.6Vikas Salgaonkar Removed highlights

and commentsJanuary 8, 2015 1.7

Kavita Nair Id Review January 12, 2015 1.8Pooja Zaware Client Feedback

Implementation-Global Changes

January 13, 2015 1.9


January 15, 2015 2.0

Shweta Mukherjee QA feedback Implementation

January 15, 2015 2.1


January 16, 2015 2.2


January 20, 2015 2.3


January 21, 2015 2.4

Priya Tiwari ID Review January 22, 2015 2.5Pooja Zaware Proofreading changes January 23, 2015 2.6Pooja Zaware Client Feedback

ImplementationJanuary 27, 2015 2.7

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January 28, 2015 2.8


February 2, 2015 2.9

Priya Tiwari Client Feedback Implementation

February 9, 2015 3.0


February 11, 2015 3.1

Pooja Zaware Client Feedback Implementation

March 23, 2015 3.2

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Ongoing Relationship Storyboard

What is a Storyboard? A storyboard or script is the preliminary version of detailed content and descriptions of the multimedia elements that will be integrated into the WBT course.

What should you review?

Does the content meet the goals of the client training requirement? Is information presented accurate? Does the flow of the content meet the instructional requirement? Do the graphics and animations illustrate the key learning points? Do the simulations and scenarios illustrate the key learning points? Does the text read appropriately?

How should you review or provide feedback?To activate the ‘Track Changes’ option in MS Word:

1. On the Review tab, click the Track Changes option in the Tracking section or2. Expand the Track Changes option3. Select Track Changes

In some of the version of MS Word, you can activate the Track Changes option by selecting it from the Tools menu.

For content language review:

Onscreen text Transcript/Voiceover text (VO)

For ID review:

Onscreen text Graphic Descriptions Transcript/Voice Over Instructions for integration or development Other specifications

Module Name: Ongoing Customer Relationship

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Slide Name: Module ObjectivesScreen No: 01

On-Screen Text Graphics Description

By the end of this module, you will be able to:

Explain the process of periodic reviews for Low/Medium and High-risk customers.

Provide an overview of event driven reviews. Identify the purpose of transaction monitoring and the role of

AML Compliance. Identify the purpose of Sanctions screenings and the role of

Office of Foreign Assets Control (OFAC)/Sanctions Central Monitoring.

Identify the information that is submitted to the board and senior management for approval.

To continue, click Next.

Display the OST in progressive disclosure format.

Image ID: 141946057

Display the above image in sync with text.

The next button should be activated only when the entire OST is displayed.

Interactivities

Course NavigationPrevious < NA Next > 02

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Module Name: Ongoing Customer RelationshipSlide Name: Know Your Customer Screen No: 02


State Street is committed to comply with AML and Sanctions regulations, as implemented by the State Street AML and Sanctions Programs. <T1>

Know your Customer (KYC) encompasses standards and procedures designed to ensure State Street knows with whom they are doing business. <T2>

Now that you have a better understanding of the three components of KYC, we are going to discuss the activities required to maintain the ongoing relationship with our customers.


Display T1 and the below image

Then display T2.

This screen is the same as the KYC screen of the module KYC at State Street.

Interactivities

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Module Name: Ongoing Customer RelationshipSlide Name: Ongoing Relationship ActivitiesScreen No: 03


Once the Customer has been onboarded, there are many activities that are required to maintain the ongoing relationship with the customer. These activities ensure that the KYC information we have on file is accurate, that we are monitoring our AML and Sanctions risks, and that State Street remains compliant with its AML and Sanctions Program as well as the regulations that drive it.

The following activities are included in ongoing relationship:

Periodic Reviews Event Driven Reviews Suspicious Activity Transaction Monitoring Ongoing Sanctions Screening Board and Senior Management Reporting

Now that you are familiar with the activities that are part of the ongoing relationship with our customers, let’s learn about these activities in detail.

Use the following image with the text on this screen:

Image ID: 215873908

The bullets will appear in the progressive disclosure format.

Interactivities

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Previous < 02 Next > 04Module Name: Ongoing Customer Relationship

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Slide Name: Periodic ReviewsScreen No: 04


<T1>In accordance with State Street’s Global AML Policy, the Business Unit and the KYC Shared Services conduct risk-based periodic reviews on all customers to ensure the KYC information is accurate and revises the customer’s risk rating, if appropriate. Business Units will be notified of upcoming reviews 90 days prior to the due date of the review.The frequency of periodic reviews is as follows:

High-risk Customer: Every year; the first review should be scheduled six months from the date in which the entity’s status in the KYC Platform reflects “verified” (the status for “approved for account opening.”)

Medium-risk Customer: Every two years Low-risk Customer: Every three years

To view enlarged periodic forms, click each image.


Display OST with below forms.

Interactivities

When the user clicks next without clicking all the forms, show the following pop-up:“You must visit both the periodic review forms before proceeding.”Display a check mark next to the button that a user has accessed.Course NavigationPrevious < 03 Next > 05

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Module Name: Ongoing Customer RelationshipSlide Name: Knowledge Check

Screen No: 05


Identify the frequency of periodic reviews for Medium-risk customers.

A. Every yearB. Half-yearlyC. Every two yearsD. Every three years

Select the correct option, and then click Submit.

Correct Answer: C

No of attempts: 1

Correct Feedback: That’s right! Periodic reviews for Medium-risk customers should be conducted every two years.

Incorrect Feedback: That’s incorrect. Periodic reviews for Medium-risk customers should be conducted every two years.

TranscriptNAInteractivitiesNACourse NavigationPrevious < 04 Next > 06

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Module Name: Ongoing Customer RelationshipSlide Name: Event Driven ReviewsScreen No: 06


An event driven review may be warranted before the next scheduled periodic review due to certain trigger events or changes related to the customer or related parties.

An event is any activity that could negatively impact the overall AML and/or Sanctions risks associated with the customer.

The Business Unit identifies an event through: Manual monitoring Information provided by the customer or from other sources

If it comes to the attention of the Business Unit that an event has taken place, KYC Shared Services should conduct an event driven review, assuming the event is such that it may negatively impact the risk.

An event driven review resets the scheduled periodic review.


Use the following image on this screen:

Image ID: 66248515

Interactivities NACourse Navigation

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Module Name: Ongoing Customer RelationshipSlide Name: Examples of Trigger EventsScreen No: 07


Some examples of trigger events include: The customer or related parties are added to Global or applicable

Local lists The customer’s or related parties’ country information changes to a

Sanctioned country Payments to or from the customer are blocked or rejected for

Sanctions reasons Information is received that suggests the customer is attempting to

circumvent Sanctions or is associated with Sanctioned parties New customer relationships (i.e., change in ownership structure) The customer undergoes a change to the legal structure/formation

of the business (i.e., going public or changing from a non-profit to a for-profit business)

Suspicious account activities The customer identifies additional controlling parties, associated

third parties, or signersTo continue, click Next.

Display the OST in a similar template provided below.

Change in Risk Level as a Result of Review

If it is determined, as part of the review, that enough information has changed to warrant a change to the AML Customer Risk Rating (CRR), the change will be documented in the customer’s profile only after a risk rating has been generated using the most current customer information.

The following table describes the actions required for Low, Medium, and Image ID: 199186658

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High-risk customers.

For customers who were Low or Medium-risk and have become High-risk

For customers who were High-risk and have become Low or Medium-risk

For customers who were Low-risk and are now considered Medium-risk, and for customers who were Medium-risk and are now considered Low-risk

The First Line of Defense conducts EDD and obtains the required signoffs from AML Compliance, Money Laundering Reporting Officer (MLRO) (where applicable), and the Business Unit Chief Operating Officer, equivalent and/or delegate.

The First Line of Defense conducts CDD. Moving to a lower risk rating requires signoffs from AML Compliance MLRO (where applicable), and the Business Unit Chief Operating Officer, equivalent and/or delegate.

The First Line of Defense obtains approval from the Business Unit Chief Operating Officer, equivalent and/or delegate.

Use the following template to represent the content:

Image ID: 178013396

Interactivities

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Module Name: Ongoing Customer RelationshipSlide Name: Suspicious ActivityScreen No: 08


It is the responsibility of all State Street employees to detect and prevent money laundering by escalating any activity or information that could possibly be associated with money laundering to management.

During the course of business, all State Street employees must be vigilant in the fight against money laundering and terrorist financing by being alert and aware of unusual activities or “red flags” associated with potential suspicious activities.

It is State Street’s policy to identify, investigate, and report suspicious activities in a complete, accurate, and timely manner.


Image ID: 207150274

State Street employees must not knowingly or through willful blindness aid and abet individuals, who attempt to violate or circumvent money laundering laws or the State Street Global AML Policy, by providing:

Advice Facilitating customer transactions using personal accounts Conducting transactions that break or obscure the audit trail

Breaches of the State Street Global AML Policy may result in disciplinary action, up to and including dismissal, civil, and/or criminal penalties. Image ID: 179203760

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Suspicious activities are defined in several ways and can involve funds derived from illegal activities:

Intended or conducted to hide or disguise funds or assets derived from illegal activities.

Designed to evade AML regulatory requirements.

Suspicious activities can appear to serve no business or apparent lawful purpose, and the financial institution can determine no reasonable explanation for a transaction after examining all available facts. Suspicious activities can also involve use of a Financial Institution (FI) to facilitate criminal activities.

Image ID: 8915674

AML Compliance monitors suspicious activities or patterns that may be inconsistent with the anticipated or expected activities for a particular customer or account.

These activities may include:

Incoming/outgoing wires Journals of funds and securities Deposits, withdrawals, and/or asset movements

Interactivities

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Module Name: Ongoing Customer RelationshipSlide Name: Red FlagsScreen No: 09


Identifying red flags is an integral part of the AML and Sanctions Compliance Program. State Street employees’ understanding of, and ability to recognize, red flags is vital to ensure timely and adequate identification and escalation of unusual or suspicious activities.

AML Compliance has developed a list of red flags to assist the First Line of Defense in identifying unusual or potentially suspicious activities.

To learn more about the list of Red Flags, click the PDF icon below.


Image ID: 178951832

To open this pdf, use the same functionality as was used in the EDD module for EDD Customer Profile screen.

If a red flag, or series of red flags is detected, the First Line of Defense must document it using the Unusual Activity Form (UAF).

The UAF should include: Description of what has happened Documentation of when it happened (list of specific

transactions/activities, dates and supporting documentation) Description of why the transaction/activity is unusual

Note: Identifying one or more red flags in a customer or transaction activity does not in and of itself indicate suspicious activity (money laundering and/or terrorist financing). However, additional care needs to

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be taken, including notifying your immediate supervisor or your Business Unit AML Officer.

Interactivities

When the user clicks next without clicking all the forms, show the following pop-up:

“You must visit all information related to Red Flags before proceeding.”

Display a check mark next to the button that a user has accessed.

Course NavigationPrevious < 08 Next >10

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Module Name: Ongoing Customer RelationshipSlide Name: Transaction Monitoring Screen No: 10


<T1> AML Compliance Financial Intelligence Unit (FIU) monitors account activity for unusual size, volume, pattern, or type of transaction, taking into account risk factors and red flags that are appropriate to each Business Unit.

Monitoring can be conducted through the following methods:

To learn more about Automated Monitoring and Manual Monitoring, click each icon below.


Use the following image:

Image 1 ID: 183272453

Display image with pop-up text.

Image ID for Automated Monitoring: 79453732

Image ID for Manual Monitoring: 21265416717

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Escalation of Suspicious Customer Behavior

If a State Street employee has reason to believe a customer’s account activity is suspicious or unlawful, they must, within one business day, notify the AML Compliance FIU, Business Unit AML Officer/MLRO and/or Business Unit Manager using the UAF.

When a suspicious activity has been identified, the Business Unit must determine whether it will terminate the customer relationship (in some cases this may be done in consultation with law enforcement).

If the suspicious activity continues, State Street may be required by law to report the suspicious activity periodically via a Suspicious Transaction Report (STR) or Suspicious Activity Report (SAR).


Display OST in progressive disclosure format with below image.

Image ID: 167861441

Interactivities

Create two tabs: Automated Monitoring Manual Monitoring

Text for interactivity:

Automated Monitoring:The AML Compliance Financial Intelligence Unit (FIU) uses a Windows® based desktop application to monitor customer account activity for the purpose of determining whether abnormal transaction patterns are present. This application filters, compiles, summarizes transaction data, and identifies instances of potentially suspicious behavior.

Manual Monitoring:

The Business Unit identifies suspicious behaviors by conducting manual monitoring of customer and account related activity.

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“You must visit all information related to Automated Monitoring and Manual Monitoring before proceeding.”

Display a check mark next to the button that a user has accessed.

Course NavigationPrevious < 09 Next >11

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Module Name: Ongoing Customer RelationshipSlide Name: Willful BlindnessScreen No: 11

On-Screen Text Graphics DescriptionIf a State Street employee deliberately avoids or ignores information that could have led to the discovery of unlawful activity to remain ignorant of the true nature of the activity, he or she will be held responsible for whatever knowledge an investigation would have revealed.

A court would find that a defendant has criminal intent if the defendant is found to have consciously and/or deliberately avoided knowledge of facts that would have disclosed a criminal activity.

A person does not have to be actively involved in assisting a laundering scheme in order to be held liable of willful blindness by law enforcement.

To the contrary, an employee who knows, or should have known that funds were tainted but still effected a banking transaction involving such funds may be charged with money laundering.


Display OST using below template. Show an employee icon. Show that his eyes are covered with ribbon as shown in next image. Do not show green checkboxes.

Image ID: 187509416


Module Name: Ongoing Customer RelationshipSlide Name: Sanctions OverviewScreen No: 12


State Street is headquartered in the U.S. and as such, all U.S. and non-U.S.-based operations are subject to Sanctions laws and regulations administered by:

• U.S. Treasury Department’s OFAC • UN Security Council• E.U. and specific Local Sanctions lists

State Street’s policy is that the requirements of OFAC are applicable globally across all of State Street’s Business Units.

Display OST with below image.

Image ID: 225260275

In general, Sanctions regulations require the following:

Blocking/freezing accounts and other property of specified countries, entities, and individuals.

Prohibiting or rejecting unlicensed trade and financial transactions with specified countries, entities, and individuals.

Governmental authorities publish Sanctions Watch lists of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries.

Watch lists contain the names of individuals, groups and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific.

Note: Sanctions review must consider the management and control of the entity and with whom State Street is contracting.

Image ID: 225260275


State Street


Module Name: Ongoing Customer RelationshipSlide Name: Sanctions ScreeningScreen No: 13


Ongoing Sanctions screening is automated and performed by (OFAC)/Sanctions Central Monitoring, and is mainly focused on existing customer screening and third party screening.

KYC Shared Services must screen the customer, both Non-Individuals and Individuals, for potential matches with Sanctioned countries at the time of onboarding.

Names and locations of the following must be screened: Customer and other related party names, such as collective

investment vehicle name, pension fund name, name of corporation for corporate cash

Beneficial Owners/Shareholders/Underlying Customers


Image: 115044784

Potential MatchesTo learn more about Confirmed Match and False Positive Match, click each icon below.

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Screening of Employees

State Street must not hire sanctioned employees or employees who reside in a Sanctioned country. Before hiring, all employees must be screened. On a weekly basis, AML Compliance must ensure all existing employees’ records are screened against Sanctions lists.

To continue, click Next.Image ID: 95386447

InteractivitiesText for interactivity:

Confirmed MatchA confirmed match is a Non-Individual or an Individual whose exact name, plus at least one other item of personal data, specifically the date of birth, identification number, or physical address and country (Individual)/physical and legal address (entity) match to an entry in the Sanctions lists.

Example:

A transaction is processed in the name of Kindhearts. As identification located in the SWIFT message, Kindhearts included a corporate address, 125 East Main Street, Toledo OH in the details field. A match is identified to an OFAC SDN, named Kindhearts for Charitable Humanitarian Development with the same address. Since the name and address match exactly to the information in the OFAC SDN

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list, this is an example of a confirmed match.

False Positive Match

A false positive match is a Non-Individual or an Individual whose name matches an entry in one of the Sanctions lists, but the accompanying personal data does not match.

Example:

In a periodic update to the SDN list, OFAC adds a name with the following description:

“ABBAS, Adbul Hussein, Italy (individual) [IRAN]”

In a review of our previously cleared transactions, we identify a potential name match for a customer Issac Hussein. Issac Hussein receives monthly payments. The filter matched the last name of the individual or entity identified in the payment message with the last name of the designated individual in the Sanctions list. This instance would be considered a false positive match because the name of the individual or organization identified in the payment message and designee in the Sanctions list do not match.


“You must visit all information related to Confirmed Match and False Positive Match before proceeding.”

Display a check mark next to the button that a user has accessed.Course NavigationPrevious < 12 Next > 14

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Module Name: Ongoing Customer RelationshipSlide Name: Sanctions ClearingScreen No: 14

On-Screen Text Graphics DescriptionPotential matches are to be addressed immediately.

Potential matches should be cleared within one business day from the day they are generated in the Sanctions screening system.

The First Line of Defense must always save research material and information used to assess the potential match in the customer’s profile. Documentation supporting the match assessment, including arguments and conclusions, needs to be filed.

To continue, click Next. Image ID: 141387034


Module Name: Ongoing Customer RelationshipSlide Name: Sanctions Escalation ProcessScreen No: 15

On-Screen Text Graphics DescriptionWhen Sanctions related alerts, whether identified at onboarding or through ongoing screening, are not cleared timely, an escalation process will be followed by AML Compliance.

Timeframe Escalating PartiesAfter five calendar days VP – Business Unit

Business Unit Sanctions Compliance OfficerSanctions-Escalation Mailbox

After 10 calendar days SVP – Business UnitBusiness Unit Sanctions Compliance Officer

Senior Compliance OfficerGlobal Chief AML Officer

Sanctions-Escalation Mailbox

After 15 calendar days EVP – Business UnitBusiness Unit Sanctions Compliance Officer

Senior Compliance OfficerGlobal Chief AML OfficerChief Compliance Officer

Sanctions-Escalation Mailbox

AML Compliance is responsible for monitoring these aging reports to ensure matches are cleared in a timely manner.


Display the OST.


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Module Name: Ongoing Customer RelationshipSlide Name: Sanctions LicensesScreen No: 16

On-Screen Text Graphics DescriptionA license is an authorization from governmental authorities (such as OFAC) to engage in a transaction that otherwise would be prohibited.

There are two types of licenses: General Licenses and Specific Licenses.

To learn more about General Licenses and Specific Licenses, click each tab below.

Note: Persons engaging in transactions pursuant to General or Specific Licenses must make sure that all conditions of the licenses are strictly observed.

Display OST in progressive disclosure format. Then display tabs with instruction.

Image ID: 107720030 (Edit the image, replace word ‘contract’ with ‘License’.

Make the interactivity as showing in OST.

Note will appear once user clicks all two tabs.

TranscriptNAInteractivitiesContent for interactivity:

Create two tabs:

General Licenses Specific Licenses

General Licenses:

This is a regulatory provision that authorizes certain transactions without filing an application with the applicable authority. Transactions consistent with normal banking practice are frequently permitted by General Licenses.

Specific Licenses:

A license granted by a governmental authority authorizing a specific transaction or set of transactions, issued on a case-by-case basis.


“You must visit all information related to General Licenses and Specific Licenses before proceeding.”

A granted license provided by authority authorizing a specific transaction or set of transactions, issued on a case-by-case basis.

Module Name: Ongoing Customer RelationshipSlide Name: Knowledge CheckScreen No: 17


Who performs automated Sanctions screening that focuses on existing customer screening and third party screening?

A. OFAC/Sanctions Central Monitoring B. AML Compliance OfficerC. Business UnitD. KYC Shared Services

Select the correct option, and then click Submit.

Correct Answer: A

No of attempts: 1

Correct Feedback: That’s right! OFAC/Sanctions Central Monitoring performs automated Sanctions screening that focuses on existing customer screening and third party screening.

Incorrect Feedback: That’s incorrect. OFAC/Sanctions Central Monitoring performs automated Sanctions screening that focuses on existing customer screening and third party screening.


State Street


Module Name: Ongoing Customer RelationshipSlide Name: Board and Senior Management ReportingScreen No: 18On-Screen Text Graphics Description

AML and Sanctions reporting to the board supports State Street’s AML and Sanctions Compliance Program that:

Outlines the governance structure, policies, procedures, and standards of State Street.

Ensures compliance with all relevant laws, codes, rules, regulations, and standards of good business practice.

The First Line of Defense is responsible for gathering relevant AML and Sanctions data for senior management and board reporting. Data can be provided on an ongoing basis, or based on ad hoc requests from either senior management and/or AML Compliance.


Image ID: 126579008

AML Compliance maintains a list of Key Risk Indicators (KRIs) and Key Performance Indicators (KPIs), which it collects from the First Line of Defense.

In addition to KRI/KPI metrics, AML Compliance and/or State Street management may request information related to:

AML and Sanctions projects and initiatives. Records of AML and Sanctions related training.

To learn more about Accounts, Activities, and Assessments, click each icon below.

Display OST in progressive disclosure format. Then display instruction with icons.

On clicking each icon, display respective text in a pop-up.

On closing the pop-up, direct the user to the main screen.

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To continue, click Next.Interactivities

Display the following icons:

Accounts Activities Assessments

Type AccountsKRI Customers (Customers)KRI AccountsKPI Funded Accounts Missing Risk RatingKPI Funded Accounts Missing DocumentationKPI Overdue Normal Risk Account ReviewsKPI Overdue Higher Risk Account ReviewsKRI Normal Risk AccountsKRI High Risk AccountsKRI High Risk Accounts ApprovedKRI High Risk Accounts DeclinedKRI Accounts in High Risk JurisdictionsKPI Accounts where UBO is a PEP

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Accounts

Activities

Assessments

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KRI Accounts for Other High Risk BusinessKRI Unauthorized Investors

Type ActivityKRI Positive Sanctions HitsKPI Sanctions Cases 1-5 DaysKPI Sanctions Cases 6-30 DaysKPI Sanctions Cases 30+ DaysKRI Potentially Suspicious Referrals to the FIUKPI Number Of Exceptions > 30 DaysKPI Number Of Exceptions > 60 DaysKRI Number Of Exceptions > 90 DaysKRI SARs Filed (by Event Type)KPI 314(a) Positive HitsKPI 314(b) Positive HitsKPI PEP Cases Aged 0-30 DaysKPI PEP Cases Aged 31-60 DaysKPI PEP Cases Aged 61-90 DaysKPI PEP Cases Aged 91+ Days

Type AssessmentsKRI AML-Related Regulatory ExaminationsKRI AML-Related Regulatory Issues ReceiveKRI AML-Related Regulatory Issues OutstandingKRI AML-Related Corporate Audit Issues ReceivedKRI AML Related Corporate Audit Issues OutstandingKRI Future Regulatory AML-Related Examinations

Expected in Current

When the user clicks next without clicking the icon, show the following pop-up:

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You must visit all information related to Accounts, Activities, and Assessments before proceeding.”

Display a check mark next to the icon that a user has accessed.Course Navigation

Previous < 17 Next > 19

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Module Name: Ongoing Customer RelationshipSlide Name: Record RetentionScreen No: 19


As a requirement, all customer facing businesses, support functions, and control functions must maintain records of a customer’s identity, transactions, and other significant records.

This ensures that legal and regulatory requirements in the jurisdictions in which it operates are met thereby ensuring confidentiality, bank secrecy, and data protection laws.

AML records must be maintained for a minimum of five years (from the end of the customer relationship in the case of identity records) or longer, if local regulation requires.

For European Union (EU) purposes, all non-transactional account records must be recorded five years from cessation of relationship, and transactional records for five years from the conclusion of the transaction.

Records must be stored to facilitate adequate access and retrieval in a timely manner.



Image ID: 44389684

Interactivities

NA

Course Navigation

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Slide Name: Module SummaryScreen No: 20On-Screen Text Graphics Description

Important points covered in this module:

KYC encompasses standards and procedures designed to ensure State Street knows with whom they are doing business.

In accordance with State Street’s Global AML Policy, KYC Shared Services conducts risk-based periodic reviews on all customers to ensure the KYC information is accurate and revise the customer’s risk rating, if appropriate. Business Units will be notified of upcoming reviews 90 days prior to the due date of the review.

An event driven review may be warranted before the next scheduled periodic review due to certain trigger events or changes related to the customer or related parties.

During the course of business, all State Street employees must be vigilant in the fight against money laundering and terrorist financing by being alert and aware of unusual activities or “red flags” associated with potential suspicious activities.

Identifying red flags is an integral part of the AML and Sanctions Compliance Program. State Street employees’ understanding of, and ability to recognize, red flags is vital to ensure timely and adequate identification and escalation of unusual or suspicious activities.

Transaction Monitoring can be conducted through Automated Monitoring and Manual Monitoring.

If a State Street employee deliberately avoids or ignores information that could have led to the discovery of unlawful activity to remain ignorant of the true nature of the activity, he or she will be held responsible for whatever knowledge an investigation would have revealed.

Sanctions screening is automated and performed by OFAC/Sanctions Central

Display bullet points in progressive disclosure format.

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Monitoring, and is mainly focused on existing customer’s screening and third party screening.

Potential matches should be cleared within one business day, from the day they are generated in the Sanctions screening system.

There are two types of licenses: General Licenses and Specific Licenses. AML and Sanctions reporting to the board supports State Street’s AML and

Sanctions Compliance Program that:o Outlines the governance structure, policies, procedures, and standards

of State Street.o Ensures compliance with all relevant laws, codes, rules, regulations,

and standards of good business practice. AML records must be maintained for a minimum of five years (from the end of

the customer relationship in the case of identity records) or longer, if local regulation requires.

Interactivities

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Documents

demos.mrccsolutions.com · Web viewBNP Paribas. Introduction Storyboard. State Street. Ongoing Customer Relationship Storyboard . State Street