Notify the Business Unit of completion of the Periodic Review Form by AML KYC AML Compliance FIU. CoE (Shared Services) Review and acknowledge the risks and any unique mitigants provided by Business Unit AML Compliance FIU. Provide the Periodic Review Form to the Business Unit Chief Operating AML KYC Officer, equivalent and/or delegate and the MLRO, in certain CoE (Shared jurisdictions, for review and sign off. Services) Sign off on the High Risk Periodic Review form to accept the risk Business Unit presented by the customer at the Business Unit level and retain the Chief documentation along with the KYC information in the KYC Platform. Operating Officer, equivalent and/or delegate Review and sign off on the and mitigating activities and/or controls to MLRO ensure they are implemented as outlined in the EDD Customer Profile and/or customer file as documented in the KYC Platform. Receive formal approval prior to increasing or decreasing the risk rating AML KYC to or from High Risk as a result of Periodic Review. CoE (Shared Services) Record all findings and attach all documentation to the KYC profile in the Business Unit KYC Platform. and AML KYC CoE (Shared Services) Record all findings and attach all documentation to the KYC profile in the Business Unit KYC Platform. and AML KYC CoE (Shared Services) 4: Event Driven Reviews Overview The event driven review process involves reviewing issues arising from customer and transaction monitoring and screening. These issues will be handled at the time they arise. 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. Where concerns are raised through these processes, these will be escalated to the Business Unit AML Officer who will determine the required course of action, which may result in closing the customer’s account, refreshing of the KYC file, or modifying the risk rating. An 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
Notify the Business Unit of completion of the Periodic Review Form by AML Compliance FIU. AML KYC CoE (Shared Services) Review and acknowledge the risks and any unique mitigants provided by AML Compliance FIU. Business Unit Provide the Periodic Review Form to the Business Unit Chief Operating Officer, equivalent and/or delegate and the MLRO, in certain jurisdictions, for review and sign off. AML KYC CoE (Shared Services) Sign off on the High Risk Periodic Review form to accept the risk presented by the customer at the Business Unit level and retain the documentation along with the KYC information in the KYC Platform. Business Unit Chief Operating Officer, equivalent and/or delegate Review and sign off on the and mitigating activities and/or controls to ensure they are implemented as outlined in the EDD Customer Profile and/or customer file as documented in the KYC Platform. MLRO Receive formal approval prior to increasing or decreasing the risk rating to or from High Risk as a result of Periodic Review. AML KYC CoE (Shared Services) Record all findings and attach all documentation to the KYC profile in the KYC Platform. Business Unit and AML KYC CoE (Shared Services) Record all findings and attach all documentation to the KYC profile in the KYC Platform. Business Unit and AML KYC CoE (Shared Services) 4: Event Driven Reviews Overview The event driven review process involves reviewing issues arising from customer and transaction monitoring and screening. These issues will be handled at the time they arise. 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. Where concerns are raised through these processes, these will be escalated to the Business Unit AML Officer who will determine the required course of action, which may result in closing the customer’s account, refreshing of the KYC file, or modifying the risk rating. An 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
StateStreet_KYC%20Platform_Participant%20Guide_V2.4_10-Mar-2015.docx