The individual or entity identified in The individual, Tony Blair, located in the new or ongoing Sanctions Livingston, Zambia, identified in the screening matched that on the new or ongoing Sanctions screening Sanctions List, which was as a potential match, was determined False Positive determined to be a false positive to be a false positive based upon based upon address/location not location/address not matching the matching the Sanctions list. Sanctions List individual, Anthony Charles Lynton Blair, London, England. The individual or entity identified in The individual, Tony Frederick Blair, of the new or ongoing Sanctions Livingston, Zambia, identified in the screening matched that on new or ongoing Sanctions screening Sanctions where the had a potential match, but was Positive potential match was determined to determined to be a false positive be a false positive based upon based upon name not matching the name and nationality/address not Sanctions List individual, Anthony matching the Sanctions List. Charles Lynton Blair of the United Kingdom. Escalation Process When Sanctions related alerts, whether identified at onboarding or ongoing screening, are not timely cleared, the following escalation process will be followed by AML Compliance: Timeframe Escalating parties VP Business Unit – After five calendar days Business Unit Sanctions Compliance Officer GS Compliance Mailbox SVP Business Unit – Business Unit Sanctions Compliance Officer ten calendar days Senior Compliance Officer Global AML Officer GS Compliance Mailbox EVP Business Unit – Business Unit Sanctions Compliance Officer After fifteen calendar days Senior Compliance Officer Global Chief AML Officer Chief Compliance Officer
False Positive The individual or entity identified in the new or ongoing Sanctions screening matched that on the Sanctions List, which was determined to be a false positive based upon address/location not matching the Sanctions list. The individual, Tony Blair, located in Livingston, Zambia, identified in the new or ongoing Sanctions screening as a potential match, was determined to be a false positive based upon location/address not matching the Sanctions List individual, Anthony Charles Lynton Blair, London, England. Positive The individual or entity identified in the new or ongoing Sanctions screening matched that on Sanctions where the potential match was determined to be a false positive based upon name and nationality/address not matching the Sanctions List. The individual, Tony Frederick Blair, of Livingston, Zambia, identified in the new or ongoing Sanctions screening had a potential match, but was determined to be a false positive based upon name not matching the Sanctions List individual, Anthony Charles Lynton Blair of the United Kingdom. Escalation Process When Sanctions related alerts, whether identified at onboarding or ongoing screening, are not timely cleared, the following escalation process will be followed by AML Compliance: Timeframe Escalating parties After five calendar days VP – Business Unit Business Unit Sanctions Compliance Officer GS Compliance Mailbox ten calendar days SVP – Business Unit Business Unit Sanctions Compliance Officer Senior Compliance Officer Global AML Officer GS Compliance Mailbox After fifteen calendar days EVP – Business Unit Business Unit Sanctions Compliance Officer Senior Compliance Officer Global Chief AML Officer Chief Compliance Officer
StateStreet_KYC%20Platform_Participant%20Guide_V2.4_10-Mar-2015.docx