Identify beneficial owners with a 10 percent (%) or greater ownership AML KYC CoE interest. (Shared Services) AML KYC CoE Utilize business applications and public domain (open source) data to (Shared Services) review and validate the provided documentation to ensure that the customer information is accurate. Conduct site visits for MSBs and other customer types where Business Unit AML applicable and document the information obtained in a report. Officer Add the site report to the customer’s KYC file in the KYC Business Unit AML Platform. Officer Use Prime and WorldCheck to screen the related parties (UBOs, AML KYC CoE controlling parties, and associated third parties) information against (Shared Services) all required lists as specified in Section 4.5.5, Screening. Contact the customer for any additional outstanding information, data Business Unit and/or documentation needed as a result of a potential match. Escalate any potential matches which cannot be dispositioned to AML KYC CoE AML Compliance for review. (Shared Services) If, based on the results of the screenings, AML and/or Sanctions Business Unit policies and guidelines will dictate the relationship is prohibited, terminate the relationship. Capture all information, data and/or documentation compiled during AML KYC CoE the gathering of requirements. (Shared Services) The following table lists the steps that the First Line of Defense performs during EDD. Step Action Owner Send an email to AML Compliance FIU that the Enhanced Due AML KYC CoE Diligence Customer Profile is available for review in the KYC (Shared Services) Platform. The Enhanced Due Diligence Customer Profile must contain the reason for rating the customer or account High Risk. Evaluate the risks presented in the Enhanced Due Diligence AML Compliance Customer Profile by the Business Unit and assign any relevant FIU unique mitigants to manage the risks, which will be captured in the Financial Intelligence Unit Assessment. Request any required additional documentation or mitigants from the AML Compliance Business Unit. FIU Contact the potential customer, if required, to gather sufficient Business Unit information to answer the specific questions from AML Compliance FIU. Complete the Financial Intelligence Unit Assessment. AML Compliance FIU This will include the enhanced procedures required to onboard the High AML Risk customer and outline the monitoring and any other
Identify beneficial owners with a 10 percent (%) or greater ownership interest. AML KYC CoE (Shared Services) Utilize business applications and public domain (open source) data to review and validate the provided documentation to ensure that the customer information is accurate. AML KYC CoE (Shared Services) Conduct site visits for MSBs and other customer types where applicable and document the information obtained in a report. Business Unit AML Officer Add the site report to the customer’s KYC file in the KYC Platform. Business Unit AML Officer Use Prime and WorldCheck to screen the related parties (UBOs, controlling parties, and associated third parties) information against all required lists as specified in Section 4.5.5, Screening. AML KYC CoE (Shared Services) Contact the customer for any additional outstanding information, data and/or documentation needed as a result of a potential match. Business Unit Escalate any potential matches which cannot be dispositioned to AML Compliance for review. AML KYC CoE (Shared Services) If, based on the results of the screenings, AML and/or Sanctions policies and guidelines will dictate the relationship is prohibited, terminate the relationship. Business Unit Capture all information, data and/or documentation compiled during the gathering of requirements. AML KYC CoE (Shared Services) The following table lists the steps that the First Line of Defense performs during EDD. Step Action Owner Send an email to AML Compliance FIU that the Enhanced Due Diligence Customer Profile is available for review in the KYC Platform. The Enhanced Due Diligence Customer Profile must contain the reason for rating the customer or account High Risk. AML KYC CoE (Shared Services) Evaluate the risks presented in the Enhanced Due Diligence Customer Profile by the Business Unit and assign any relevant unique mitigants to manage the risks, which will be captured in the Financial Intelligence Unit Assessment. AML Compliance FIU Request any required additional documentation or mitigants from the Business Unit. AML Compliance FIU Contact the potential customer, if required, to gather sufficient information to answer the specific questions from AML Compliance FIU. Business Unit Complete the Financial Intelligence Unit Assessment. This will include the enhanced procedures required to onboard the High AML Risk customer and outline the monitoring and any other AML Compliance FIU
StateStreet_KYC%20Platform_Participant%20Guide_V2.4_10-Mar-2015.docx