Topic 11: Board and Senior Management Reporting Overview 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 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. AML Compliance maintains a list of Key Risk Indicators (KRIs) and Key Performance Indicators (KPIs), 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. The following table provides details about KRI/KPI for Accounts, Activity, and Assessments. Accounts Activity Assessments Positive Sanctions Hits AML-Related Regulatory Customers (Customers) Sanctions Cases 1-5 Examinations Accounts Days AML-Related Regulatory Funded Accounts Missing Sanctions 6-30 Issues Receive Risk Rating Days AML-Related Regulatory Funded Accounts Missing Sanctions Cases 30+ Issues Outstanding Documentation Days AML-Related Corporate Overdue Normal Risk Potentially Suspicious Audit Issues Received Account Reviews Referrals to the FIU AML Related Corporate Overdue Higher Risk Number Of Exceptions > Audit Issues Outstanding Account Reviews 30 Days Future Regulatory Normal Risk Accounts Number Of Exceptions > Examinations High Risk Accounts 60 Days Expected in Current High Risk Accounts Number Of Exceptions > Approved 90 Days High Risk Accounts SARs Filed (by Event Declined Type) Accounts in High Risk 314(a) Positive Hits Jurisdictions 314(b) Positive Hits Accounts where UBO is a PEP Cases Aged 0-30 PEP Days Accounts for Other High PEP Cases Aged 31-60 Risk Business Days Unauthorized Investors PEP Cases Aged 61-90 Days PEP Cases Aged 91+ Days
Topic 11: Board and Senior Management Reporting Overview 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 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. AML Compliance maintains a list of Key Risk Indicators (KRIs) and Key Performance Indicators (KPIs), 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. The following table provides details about KRI/KPI for Accounts, Activity, and Assessments. Accounts Activity Assessments Customers (Customers) Accounts Funded Accounts Missing Risk Rating Funded Accounts Missing Documentation Overdue Normal Risk Account Reviews Overdue Higher Risk Account Reviews Normal Risk Accounts High Risk Accounts High Risk Accounts Approved High Risk Accounts Declined Accounts in High Risk Jurisdictions Accounts where UBO is a PEP Accounts for Other High Risk Business Unauthorized Investors Positive Sanctions Hits Sanctions Cases 1-5 Days Sanctions 6-30 Days Sanctions Cases 30+ Days Potentially Suspicious Referrals to the FIU Number Of Exceptions > 30 Days Number Of Exceptions > 60 Days Number Of Exceptions > 90 Days SARs Filed (by Event Type) 314(a) Positive Hits 314(b) Positive Hits PEP Cases Aged 0-30 Days PEP Cases Aged 31-60 Days PEP Cases Aged 61-90 Days PEP Cases Aged 91+ Days AML-Related Regulatory Examinations AML-Related Regulatory Issues Receive AML-Related Regulatory Issues Outstanding AML-Related Corporate Audit Issues Received AML Related Corporate Audit Issues Outstanding Future Regulatory Examinations Expected in Current
StateStreet_KYC%20Platform_Participant%20Guide_V2.4_10-Mar-2015.docx