Negative News All customers, UBOs and any related and specified controlling parties, and associated third parties must be screened for negative news items, and once analyzed, should be designated as relevant or non-relevant. Negative news can be classified as relevant negative news and non-relevant negative news. The following table provides details related to relevant negative news and non-relevant negative news. Non-Relevant Negative News Relevant Negative News Relevant Negative News is when the customer Non-relevant negative news largely pertains to poses a High-risk. less significant instances of the activities described above. The offenses are typically Generally, only negative information that reflects isolated and/or minor in nature. the reputation of the customer for legal or regulatory compliance is relevant, such as: Non-relevant negative news corresponds to incidents that reflect no significant reputational, Criminal or regulatory enforcement actions legal, or financial impact on the customer. Money laundering or Sanctions violations It should be noted that, multiple instances of a non-relevant behavior that appear to suggest Other illegal activity that was conducted by or control issues for an individual or institution facilitated by the customer may collectively be interpreted as relevant. Negative financial news or information litigation with customers or competitors also generally is not relevant. Crimes committed against the customer generally may not be relevant, such as embezzlement and/or traffic violation. If there is any doubt whether negative news is relevant, the Business Unit AML Officer must be consulted. In the case of a confirmed match and materiality, the Business Unit will contact the Business Unit AML Officer and AML Compliance Financial Intelligence Unit (FIU) on the same day. The following table lists examples of relevant and non-relevant negative news that includes but is not limited to a customer’s and/or related party’s established or reasonably substantiated connections. Relevant Negative News Non-Relevant Negative News Terrorist activity related to AML Misdemeanor criminal convictions or judgments AML and Sanctions non-compliance Unremarkable civil awards, settlements or penalties Violations of AML laws, regulations or sanctions Insignificant or extraneous litigation Drug-related offenses due to cash intensive Rogue employee actions nature increases AML Risk
Negative News All customers, UBOs and any related and specified controlling parties, and associated third parties must be screened for negative news items, and once analyzed, should be designated as relevant or non-relevant. Negative news can be classified as relevant negative news and non-relevant negative news. The following table provides details related to relevant negative news and non-relevant negative news. Relevant Negative News Non-Relevant Negative News Relevant Negative News is when the customer poses a High-risk. Generally, only negative information that reflects the reputation of the customer for legal or regulatory compliance is relevant, such as: Criminal or regulatory enforcement actions Money laundering or Sanctions violations Other illegal activity that was conducted by or facilitated by the customer Negative financial news or information litigation with customers or competitors also generally is not relevant. Crimes committed against the customer generally may not be relevant, such as embezzlement and/or traffic violation. If there is any doubt whether negative news is relevant, the Business Unit AML Officer must be consulted. In the case of a confirmed match and materiality, the Business Unit will contact the Business Unit AML Officer and AML Compliance Financial Intelligence Unit (FIU) on the same day. Non-relevant negative news largely pertains to less significant instances of the activities described above. The offenses are typically isolated and/or minor in nature. Non-relevant negative news corresponds to incidents that reflect no significant reputational, legal, or financial impact on the customer. It should be noted that, multiple instances of a non-relevant behavior that appear to suggest control issues for an individual or institution may collectively be interpreted as relevant. The following table lists examples of relevant and non-relevant negative news that includes but is not limited to a customer’s and/or related party’s established or reasonably substantiated connections. Relevant Negative News Non-Relevant Negative News Terrorist activity related to AML Misdemeanor criminal convictions or judgments AML and Sanctions non-compliance Unremarkable civil awards, settlements or penalties Violations of AML laws, regulations or sanctions Insignificant or extraneous litigation Drug-related offenses due to cash intensive nature increases AML Risk Rogue employee actions
StateStreet_KYC%20Platform_Participant%20Guide_V2.4_10-Mar-2015.docx