The following table lists the steps that the First line of defense performs for low and medium risk customers. Step Action Owner Contact the appropriate Business Unit representative 90 calendar days in AML KYC CoE advance of the Periodic Review. (Shared Services) Remember: Low is every three years and Medium is every two years. all data elements into the required/specific fields in the Periodic AML KYC CoE Review Form and retain the form in the KYC Platform after obtaining all (Shared required information, data and/or documentation per the AML KYC Services) Requirements Matrix. Review the information, data, and/or documentation received from the AML KYC CoE customer, including beneficial ownership. (Shared Services) Contact the customer if any of the required information, data, and/or Business Unit documentation for the Periodic Review Form cannot be obtained. Validate that all customer KYC information is up to date and accurate in AML KYC CoE the customer’s KYC file in the KYC Platform and all customer profiles and (Shared associated cases (e.g. alerts, investigation and remediation results) are up Services) to date and accurate. Determine if there are any material changes to the customer’s original AML KYC CoE information. (Shared Services) Re-screen the following customer (account/account holder) and AML KYC CoE associated party information against all the required lists as noted in (Shared Section 4.5.5, Screening, using Prime and Worldcheck: Services) Customer’s full name/business name; Parent holding companies; Owners of the business; Board of Directors; Senior Management; and Country of domicile and country of residence, for the individuals for whom it is required to be obtained as part of onboarding per the KYC Requirements Matrix, should also be reviewed to ensure the BU does not enter into a relationship with prohibited countries. See the Global Sanctions Policy for more information. Review the actual activity against the previously documented expected Business Unit profile. The following table lists the steps that the First line of defense performs for low and medium risk customers. Step Action Owner
The following table lists the steps that the First line of defense performs for low and medium risk customers. Step Action Owner Contact the appropriate Business Unit representative 90 calendar days in advance of the Periodic Review. Remember: Low is every three years and Medium is every two years. AML KYC CoE (Shared Services) all data elements into the required/specific fields in the Periodic Review Form and retain the form in the KYC Platform after obtaining all required information, data and/or documentation per the AML KYC Requirements Matrix. AML KYC CoE (Shared Services) Review the information, data, and/or documentation received from the customer, including beneficial ownership. AML KYC CoE (Shared Services) Contact the customer if any of the required information, data, and/or documentation for the Periodic Review Form cannot be obtained. Business Unit Validate that all customer KYC information is up to date and accurate in the customer’s KYC file in the KYC Platform and all customer profiles and associated cases (e.g. alerts, investigation and remediation results) are up to date and accurate. AML KYC CoE (Shared Services) Determine if there are any material changes to the customer’s original information. AML KYC CoE (Shared Services) Re-screen the following customer (account/account holder) and associated party information against all the required lists as noted in Section 4.5.5, Screening, using Prime and Worldcheck: Customer’s full name/business name; Parent holding companies; Owners of the business; Board of Directors; Senior Management; and Country of domicile and country of residence, for the individuals for whom it is required to be obtained as part of onboarding per the KYC Requirements Matrix, should also be reviewed to ensure the BU does not enter into a relationship with prohibited countries. See the Global Sanctions Policy for more information. AML KYC CoE (Shared Services) Review the actual activity against the previously documented expected profile. Business Unit The following table lists the steps that the First line of defense performs for low and medium risk customers. Step Action Owner
StateStreet_KYC%20Platform_Participant%20Guide_V2.4_10-Mar-2015.docx