demos.mrccsolutions.com · web viewif the material discrepancy cannot be resolved and...

State Street

Customer Identification Program Storyboard

Storyboard

Customer Identification Program

Information Classification: Limited Access

State Street


DOCUMENT HISTORY

Created/Revised By

Revision Details Created/Revised on Version No

Pooja Zaware Initial Draft Nov 6, 2014 0.1Shweta Mukherjee ID Review Nov 7, 2014 1.0

Pooja Zaware Client Feedback Implementation

Nov 13, 2014 1.1

Shweta Mukherjee Client Feedback Implementation

Nov 14, 2014 1.2

Vikas Salgaonkar Client Feedback Implementation

Nov 17, 2014 1.3


Nov 18, 2014 1.4


Nov 20, 2014 1.5

Shweta Mukherjee Client Feedback Implementation on

Screen 5

Nov 21, 2014 1.6


Nov 24, 2014 1.7


Nov 25, 2014 1.8

Shweta Mukherjee Client Feedback Implementation on

screen 4 and 5

Nov 26, 2014 1.9


Dec 1, 2014 2.0


Dec 2, 2014 2.1

Shweta Mukherjee ID review Dec 3, 2014 2.2Shweta Mukherjee QA review Dec 5, 2014 2.3Shweta Mukherjee Client Feedback

ImplementationDec 8, 2014 2.4

Shweta Mukherjee Client Feedback Dec 9, 2014 2.5


State Street


ImplementationVikas Salgaonkar Client Feedback

ImplementationDec 11, 2014 2.6


Dec 12, 2014 2.7

Vikas Salgaonkar Changes in Summary

Dec 12, 2014 2.8


Dec 19, 2014 2.9


Jan 08, 2015 3.0

Megha Arya Client Feedback Implementation

Jan 12, 2015 3.1


Jan 13, 2015 3.2


Jan 14, 2015 3.3

Shweta Mukherjee QA changes and document cleaning

Jan 14, 2015 3.4

Pooja Zaware ID Verification and Global changes Implementation

Jan 15, 2015 3.5


Jan 16, 2015 3.6


Jan 19, 2015 3.7

Pooja Zaware SB updates Jan 20, 2015 3.8Pooja Zaware Global changes and

Proofreading changes

Jan 22, 2015 3.9

Vikas Salgaonkar Clean Version Jan 22, 2015 4.0Pooja Zaware Client Feedback

ImplementationJan 27, 2015 4.1


Jan 28, 2015 4.2


State Street


Priya Tiwari Client Feedback Implementation

Feb 4, 2015 4.3


Feb 4, 2015 4.4


Feb 11, 2015 4.5


March 23, 2015 4.6


April 24, 2015 4.7


State Street


What is a Storyboard?

A storyboard or script is the preliminary version of detailed content and descriptions of the multimedia elements that will be integrated into the WBT course.

What should you review?

Does the content meet the goals of the client training requirement? Is the information presented accurate? Does the flow of the content meet the instructional requirement? Do the graphics and animations illustrate the key learning points? Do the simulations and scenarios illustrate the key learning points? Does the text read appropriately?

How should you review or provide feedback?

To activate the ‘Track Changes’ option in MS Word:

1. On the Review tab, click the Track Changes option in the Tracking section or2. Expand the Track Changes option3. Select Track Changes

In some of the version of MS Word, you can activate the Track Changes option by selecting it from the Tools menu.

For content language review:

Onscreen text Transcript/voice-over text (VO)

For ID review:

Onscreen text Graphic Descriptions Transcript/Voice Over


State Street


Instructions for integration or development Other specifications


State Street


Module Name: Customer Identification Program

Slide Name: Module Objectives

Screen No: 01

On-Screen Text Graphics DescriptionBy the end of this module, you will be able to:

Implement CIP on each customer who opens an account.

Determine the customer type. Identify information and documents required to

perform, validate, and verify customer identification. Acquire an understanding of how the Know Your

Customer (KYC) Requirements Matrix supports the Customer Identification Program (CIP).

Identify the criteria that results in a CIP exemption/Simplified Due Diligence (SDD).

To continue, click Next.

Display the OST in progressive disclosure format.

Image ID: 141946057

Display the above image in sync with text.

The next button should be activated only when the entire OST is displayed.

TranscriptNAInteractivitiesNACourse NavigationPrevious < NA Next > 02

7


State Street



Slide Name: Know Your Customer

Screen No: 02

On-Screen Text Graphics DescriptionState Street is committed to comply with Anti-Money Laundering (AML) and Sanctions regulations as implemented by the State Street AML and Sanctions Programs. T1

KYC encompasses standards and procedures designed to ensure State Street knows with whom they are doing business. T2

Now that you have a better understanding of KYC, this module will provide detailed information related to the first component of KYC: CIP. T3


Display T1 and the below image

Then, display T2 and T3.

Transcript

NAInteractivities

NACourse Navigation

Previous < 01 Next > 03

8


Non-Individuals and Individuals

State Street


9



Slide Name: Customer Identification Program

Screen No: 03

On-Screen Text Graphics DescriptionThe State Street Global AML Policy requires the First Line of Defense to implement CIP for the purpose of identifying and verifying the identity of each customer who opens an account. As per this policy: T1

The Business Unit must be able to identify the true identity of the customer.

The Business Unit obtains the identification information for each customer.

KYC Shared Services performs verification for each customer.


Display T1 and the below image.

Image ID: 176522504Modify text on the image to read “State Street Global AML Policy”

Create Tool Tip for ‘First Line of Defense’.

Text for tool Tip: First Line of Defense consists of the Business Unit and KYC Shared Services.”

The animation will be played with this screen.

Slow down the animation using the translation table and show only the first four examples.

The animation should finish properly. It continues on for a bit.

To learn more about the identification process for a customer, click the icon below.


Display the instruction followed by the icon on the screen. On clicking the Non-Individuals and Individuals icon, show the following animation:

1. Show an animation of a customer approaching State Street to open an account. Display the text “When a customer (Image ID: 124467403) approaches State Street to open an account, the First Line of Defense obtains identification information of each customer.”

When a customer approaches State Street to open an account, the 1st Line of Defense identifies, validates, and verifies the identity of each customer.

After the customer is identified, the Business Unit uses the Translation Table to determine the customer type.

Translation Table

Customer Type

Business Unit

Business UnitKYC Requirements

Matrix

After the customer type is identified, the Business Unit uses the KYC Requirements Matrix to identify the requirements for CIP. If the customer and account are different,

requirements for both entities must be identified.

Customer Customer

Notice

Customer Exa Customer

Notice Example

State Street


10



Slide Name: Customer Notice

Screen No: 04

On-Screen Text Graphics Description

All Business Units are required to provide U.S. customers with adequate notice that State Street is requesting information to verify their identity. (T1)

Business Units must maintain evidence that adequate customer notice has been provided in accordance with the AML Monitoring & Surveillance (M&S) Oversight Program.

To learn more about the customer notice, click each icon below.


Display T1 and the instruction on the screen.

Then display the following icons along with labels.

First Image ID: 113886565 Second Image ID:119453605

On clicking each icon, respective text and images will appear in pop-ups.

On closing a pop-up, direct the user to the main screen.

TranscriptNAInteractivitiesCreate two icons on the screen: Customer Notice and Customer Notice Example.

Text for pop-ups:

Customer Notice:

The customer notice should/will be:

Available in various forms depending on the manner in which the customer opens an account. Adequate if the Business Unit gives a general description of the identification requirements. Adequate if the Business Unit provides it in a way that is reasonably designed to ensure that customers can see it or know about it

before opening an account.

Customer Notice Example:

The Business Units must use the following text when providing the customer notice.

State Street



Slide Name: Identification of Ownership Structure

Screen No: 05

On-Screen Text Graphics DescriptionAs part of CIP, information about the true identity of a Non-Individual or an Individual on whose behalf a customer’s account is opened, a relationship is established, or a significant transaction is conducted must be obtained and retained.

The required CIP information that must be obtained varies based on the legal structure or customer type for which the relationship was established and is commensurate with risks of the customer.

The KYC Requirements Matrix outlines the documents/information by customer type to be collected by the Business Unit as part of the CIP process.


Display OST with below image:

Image ID: 92333173

Transcript

Interactivities

Course Navigation Previous < 04 Next > 06

11


Non-Individuals Individuals Controlling/Associated Third Parties

State Street


12



Slide Name: Required Information for Customer Identification

Screen No: 06

On-Screen Text Graphics DescriptionThe Business Unit must obtain and retain the following minimum identification information from each:

New customer seeking to open an account. New person being added to an existing customer’s account. Existing customer seeking to open a new account.

To learn more about customer identification information the Business Unit needs to obtain, click each icon below.


Display instruction and following icons with labels.

On clicking each icon, respective text and images will appear in pop-ups.

Image ID for Non-Individuals: 225600154

Image ID for Individuals:141032806

Controlling Parties: 111869576

TranscriptNAInteractivitiesOn clicking each icon, display respective text in pop-ups.Text for pop-ups:Non-Individuals

To identify Non-Individuals, you need to obtain:

Full business or legal entity name (Contracting Party) Physical address and country:

State Street



Slide Name: Knowledge Check

Screen No: 07


Identify the information that the Business Unit must obtain from a customer as part of CIP.

A. Name B. Physical AddressC. Date of Birth, when ApplicableD. Identification NumberE. All of the above

Select the correct option, and then click Submit.

Correct Answers: ENo of attempts: 1Correct Feedback: That’s right! The Business Unit must obtain the name, physical address, date of birth, and identification number from a customer as part of CIP.

Incorrect Feedback: That’s incorrect. The Business Unit must obtain the name, physical address, date of birth, and identification number from a customer as part of CIP.

TranscriptNAInteractivitiesNACourse Navigation06 < Previous Next > 08

13


XDocumentary

MethodNon-Documentary

Method

State Street



Slide Name: Documentary and Non-Documentary Methods of Identification

Screen No: 08


Verification of the customer’s identity is performed by KYC Shared Services to ensure that the Business Unit’s assessment of the appropriateness of the new customer or controlling/associated third party is based on true and accurate information. (T1)

To learn more about documentary and non-documentary methods of verifying a customer, click each icon below.


Display T1 and the instruction following it on the screen.

Then display the icons along with labels: Documentary and Non-Documentary Method on the screen.

Documentary and Non-Documentary Method Image ID: 156054245

For Non-Documentary Method icon, show a cross along with the icon of a document.

On clicking each icon, display respective text along with images in pop-ups.

On closing the pop-up, direct the user to the main screen.

Image for Documentary Method Pop-up: 126278501

14


State Street


Image for Non-Documentary Method: 163201424

TranscriptNAInteractivitiesDisplay two images as ‘Documentary’ and ‘Non-Documentary’. When a user clicks an image, display text in a pop-up.

Text corresponding to respective buttons is given below.

15


State Street


Documentary Method

Purpose

Methods that rely on verifying the customer’s identity through the inspection of physical documents.

Where to Locate the Requirements

Acceptable forms of documentary verification are outlined in the Global AML and Sanctions Business Unit Standard Operating Procedures.

Requirements

For an existing customer, identification may be verified by the following:

- Unexpired existing documents on file- Annotating the information and source, as long as such documents meet current standards and were valid at the time

obtained

Customer verification can be performed via a public domain using:

- Email- Faxed copy or hard copy

Note: If documents are not in English, a certification that confirms the appropriateness of the document may be relied upon.

Certain jurisdictions do not allow Financial Institution (FI) to make a photocopy of a customer’s identification document. If a photocopy or image of the document is not retained, a record must be made with a description for the relevant document.

If documentary verification is used, the following needs to be retained:- Description of the document that was used, noting the type of document

16


State Street


- Any identification number contained in the document- Place of issuance - Date of issuance- Expiration date

Use of Non-Standard Verification

If a Business Unit seeks to verify a customer’s identity using a documentary means that is not listed in the Global AML and Sanctions

Business Unit Standard Operating Procedures, it must be approved by the Global Chief AML Officer. The Global Chief AML Officer will determine if the identification document proposed is acceptable, for a one-time exception. The Global Chief AML Officer’s approval must be documented and retained.

Non-Documentary Method

Purpose

Methods that rely on verifying the customer’s identity through the collection of customer information using non-documentary sources, for example:

o Banker’s Almanaco Bloombergo Bureau Van Dijk – ORBIS

Where to Locate the Requirements

Acceptable forms of non-documentary verification are outlined in the Global AML and Sanctions Business Unit Standard Operating Procedures.

Requirements

17


State Street


A copy or screen print of the non-documentary source should be retained. If a copy or screen print is unavailable, a record must be made to identify the non-documentary method used. The record

should include the following:- Date of the review of the non-documentary source- Description of the method used- Results, including if no record was found

All non-documentary verifications must be retained as part of the customer profile within the KYC Platform for five years after the record is made or longer, if required by local regulations.

This may include:- The results of any measures undertaken to verify the identity of the customer- The results of any measures undertaken to verify the identity of additional controlling persons - A description of resolution of any substantive discrepancies that were discovered when verifying identifying information

Use of Non-Standard Verification

If a Business Unit seeks to verify a customer’s identity using a non-documentary means that is not listed in the Global AML and Sanctions Business Unit Standard Operating Procedures, it must be approved by the Global Chief AML Officer. The Global Chief AML Officer will determine if the identification method proposed is acceptable, for a one-time exception. The Global Chief AML Officer’s approval must be documented and retained.

When the user clicks next without clicking all the icons, show the following pop-up:

“You must visit each of the documentary and non-documentary procedural steps before proceeding.”

Display a check mark next to the icon that a user has accessed.

Course NavigationPrevious < 07 Next >

18


State Street


09

19


State Street



Slide Name: Acceptable and Unacceptable Identification Documents

Screen No: 09

On-Screen Text Graphics DescriptionTo learn more about Acceptable Non-Individual Documents, Acceptable Individual Documents, and Unacceptable Documents, click each icon below.


Display the three icons along with labels.

Images for icons:

Acceptable Individual Documents Image ID: 116562256

Acceptable Non-Individuals Documents Image ID: 152066015

Unacceptable Documents Image ID: 152066015

On clicking each icon, display respective text and images in pop-ups.


Images for pop-ups:

Acceptable Individual Documents: 51593650

20


http://www.shutterstock.com/pic-51593650.html

State Street


Acceptable Non-Individual Documents: 116562256

Unacceptable Documents: 129148805

TranscriptNAInteractivitiesCreate three icons for Acceptable Individual Documents, Acceptable Non-Individuals Documents, and Unacceptable Documents.

Text for pop-ups:

Acceptable Non-Individual Documents:

Acceptable identification documents for Non-Individuals include:

A copy of banking license (banks only) For jurisdictions that do not issue physical banking licenses,:

o A screenshot of the regulator’s website, confirming regulated status 21


http://www.shutterstock.com/pic-129148805.html

State Street


o The issue date of license and permissions/restrictions associated, sufficient to confirm whether counterparty is an offshore bank

For other foreign FIs other than banks, a copy of the license or authority under which the FI operates, issued by the country of incorporation

Articles of Incorporation Articles of Association/Organization Signed Limited Partnership Agreement Signed General Partnership Agreement LLC Operating Agreement Full Trust Agreement or copies of relevant pages Certificate of Trade or Business Name

Note: A full list of acceptable documents can be found in the KYC Requirements Matrix.

Acceptable Individual Documents:

Acceptable identification documents for Individuals include:

Government Issued Identification Card Driver’s License Passport (any, with photograph) US Passport Card (with photograph) Military Identification or dependent’s Military Identification Card Consular Identification Card Tribal Identification Card


22


State Street


Unacceptable Documents

Unacceptable identification documents include:

Social Security Card, except for accounts for minors and seniors Non-personalized cash cards Student ID cards Rail cards Club membership cards



“You must visit all information related to Acceptable Non-Individual Documents, Acceptable Individual Documents, and Unacceptable Documents before proceeding.”


Course NavigationPrevious < 08 Next > 10

23


State Street




Screen No: 10


Identify information that needs to be included in the document when using the documentary verification method.

A. Version of the documentB. Issuer of the documentC. Reviewer of the documentD. Place and date of review of the document

Select the correct option, and then click Submit.

Correct Answer: B

No of attempts: 1

Correct Feedback: That’s right! A record made to verify the identity of the customer using the documentary method includes the name of the issuer of the document.

Incorrect Feedback: That’s incorrect. A record made to verify the identity of the customer using the documentary method includes the name of the issuer of the document.

TranscriptNAInteractivitiesNACourse Navigation9 < Previous Next > 11

24


CIP Exemptions/SDD

State Street



Slide Name: Customer Identification Program Exemptions/Simplified Due Diligence

Screen No: 11

On-Screen Text Graphics DescriptionA CIP exemption, often referred to as SDD, is a reduced form of due diligence in specific circumstances only, and is considered appropriate for certain customers where the money laundering or terrorist financing risk is deemed to be lower. (T1)

To learn more about CIP exemptions/SDD, click the image below.

Note:

Display T1 and the instruction following it on the screen.

Then images with label CIP Exemptions/SDD

Image ID: 74510059

CIP Exceptions image ID: 110545871

On clicking image, display respective text and images in pop-ups.


Display T2 in progressive disclosure format.

Images for pop-ups:

Image for Financial institution: 99647729

25


State Street


CIP Exemptions/SDD must adhere to relevant legislation and be in line with State Street’s AML Risk Assessment.

CIP Exemptions/SDD can only be applied to the designated customer types, as referenced in the KYC Requirements Matrix.

CIP Exemptions/SDD can only be applied if there are no indicators of heightened risk, such as PEP status or relevant negative news.

CIP Exemptions/SDD does not preclude the necessity of performing due diligence on a customer. It simply precludes the necessity for having to verify the identity of a customer. T2


Image for Governmental entity: 104502059

TranscriptNAInteractivitiesDisplay two images as ‘SDD’ and ‘CIP Exceptions’. When a user clicks an image, display text in a pop-up.

Text for pop-up:

CIP Exemptions/SDD:

Customers qualifying for CIP exemption do not need to share copies of licenses or charters. The exempted customers include:

FIs with a regulator- Confirmation of the regulated status for FIs must be established through the regulator’s or self-regulatory organization’s

website. Public companies traded on an approved stock exchange

- Confirmation must include their listed status established through appropriate market data sources, such as Stock Exchange 26


State Street


website, and supporting documentation obtained concerning exchange and registration. Governmental entities

- Confirmation must include documentation certifying their exempt status. Accounts opened for the purpose of participating in an employee benefit plan established under the Employee Retirement

Income Security Act of 1974 (ERISA), or similar, are excluded from the definition of an account and not subject to CIP.- Confirmation must include IRS form 5500, or a copy of the plan or other document demonstrating that the plan is an ERISA

plan.


“You must visit all information related to CIP exemptions before proceeding.”


Course NavigationPrevious <10 Next > 12

27


State Street



Slide Name: Handing off to KYC Shared Services

Screen No: 12


Before submitting information and documents to KYC Shared Services, the Business Unit must validate and ensure that what is being handed off is:

Current: The information must be up to date and not expired. Legible: The Business Unit must be able to read all of the required data elements in the

documentation and clearly see the photos in order to easily identify the customer in the ID. Signed and in full (if applicable): Any documents that require a signature must be signed

and all pages obtained. Annotated: The Business Unit must annotate the documents if they are in a language other

than English.


Display OST with below image.

Image ID: 212654167

TranscriptNAInteractivitiesNACourse NavigationPrevious < 11 Next > 13Module Name: Customer Identification Program

28


State Street


Slide Name: Material Discrepancies

Screen No: 13

On-Screen Text Graphics DescriptionIn the course of verifying the identity of a customer, material discrepancies may arise between:

Information obtained from the customer Information obtained during the verification process

Example: TIN or address that does not match with what the customer originally provided. T1

In these instances, KYC Shared Services may use one or more of the following steps to resolve such material discrepancies before the customer’s account is opened:

1. Confirm information received from the customer is correct.2. Verify identity through additional means. T2

To view an example of material discrepancies, click the button below.

For T1, create an animation showing the address of a customer on passport or license and a bank form where a different address is filled for the same customer. Show an alert sign to show that the situation is alarming.

Images: 206690428, 139888051

Display the following two addresses on the bank document and the license:

Address 1: FLAT NO. 100, TRIVENI APARTMENTS, PITAM PURA, NEW DELHI 110034, INDIAAddress 2: FLAT NO. 302, OASIS HEIGHTS, LODHI ROAD, NEW DELHI 110003, INDIA

29


Example

State Street


If material discrepancies cannot be resolved, KYC Shared Services is responsible for:

Alerting the Business Unit and Business Unit AML Officer. Providing details of what customer information does not match, including the documentation

sources where the customer information can be found. Maintaining a record of such material discrepancies by documenting it and its resolution in

the customer’s profile.T3

Use the following image with T3:

Image ID: 208534750

If the material discrepancy cannot be resolved and verification cannot be completed, the customer’s account cannot be opened and the matter must be considered by AML Compliance for suspicious activity reporting.

Discrepancies not deemed to be material might include inability to verify an address – for instance, a recent change of resident/office.

All records related to the discrepancies made in the course of verifying identification of customers and how the discrepancy was resolved must be documented in the customer’s profile and maintained for a period of at least five years from the date of the record. T4

Use the following image with T4 and the text that follows:

Image: 92100191

TranscriptNAInteractivitiesWhen the user clicks next without clicking all the icons, show the following pop-up:

“You must visit all information related to material discrepancies before proceeding.”


30


State Street


Course NavigationPrevious < 12 Next > 14

31


State Street




Screen No: 14


Before submitting information and documents to KYC Shared Services, the Business Unit ensures that the document is ________.

A. CurrentB. LegibleC. Signed in fullD. Annotated, if not in EnglishE. All of the above

Select correct option, and then click Submit.

Correct Answer: E

No of attempts: 1

Correct Feedback: That’s right! Before submitting information and documents to KYC Shared Services, the Business Unit ensures that the document is current, legible, signed and in full (if applicable), and annotated, if in a language other than English.

Incorrect Feedback: That’s incorrect. Before submitting information and documents to KYC Shared Services, the Business Unit ensures that the document is current, legible, signed and in full (if applicable), and annotated, if in a language other than English.

TranscriptNAInteractivitiesNACourse NavigationPrevious < 13 Next > 15

32


State Street


Module Name: Customer Identification Program Slide Name: Record RetentionScreen No: 15


The Business Unit and AML Compliance must maintain records of all Unusual Activity Forms (UAFs) and supporting documentation for five years after the date when the account was closed or longer, if required by local regulations.

To learn more about record retention, click each icon below.


Use the following image with the text on this screen:

Image ID: 44389684

Create two tabs and fade them below the OST.

Tab 1: Retention of Records Relating to Customer Identification

Tab 2: Retention of Records Relating to Customer Verification

Tab 1 Image: ID: 221409634

33


State Street


Tab 2 Image: ID: 162018140InteractivitiesContent related to each tab is given below:

Tab 1: Retention of Records Relating to Customer Identification The Business Unit must retain all information obtained as part of Customer Identification for five years after the date when the account is closed or longer, if required by local regulations. At a minimum, the record must include all identifying information obtained about the customer (name, address, date of birth for an Individual, government identification number, and any other information required by CIP).

Tab 2: Retention of Records Relating to Customer Verification If documentary verification is used, a description of the document that was used, noting the type of document, any identification number contained in the document, the place of issuance and, if any, the date of issuance and expiration date must be retained for five years from the date of record or longer, if required by local regulations. If non-documentary verification is used, a description of the results of any measures undertaken to verify the identity of the customer must be retained for five years after the record is made or longer, if required by local regulations. In the case of additional verification of control persons performed for Non-Individual customers, a description of the results of any measures undertaken to verify the identity of the customer must be retained for five years after the record is made. Additionally, a description of resolution of any substantive discrepancies that were discovered when verifying identifying information must be retained for five years from the date of record.

34


State Street


When the user clicks next without clicking all the tabs, show the following pop-up:

You must visit all information related to record retention before proceeding.


Course Navigation

Previous < 14 Next > 16

35


State Street



Slide Name: Module Summary

Screen No: 16

On-Screen Text Graphics DescriptionImportant points covered in this module:

The State Street Global AML Policy requires the First Line of Defense to implement CIP for the purpose of identifying and verifying the identity of each customer who opens a new account.

After the customer type is identified, the Business Unit uses the KYC Requirements Matrix to understand the requirements for CIP.

A CIP exemptions, often referred to as SDD, is a reduced form of due diligence in specific circumstances only, and is considered appropriate for customers where the money laundering or terrorist financing risk is deemed to be lower.

After the Business Unit gathers the necessary information and documents, KYC Shared Services must verify the identity of a customer through documentary or non-documentary means, or through a combination of both to form a reasonable belief that it knows the true identity of the customer.

KYC Shared Services may use one or more of the following steps to resolve material discrepancies before the customer’s account is opened:

1. Confirm that the information received from the customer is correct.2. Verify identity through additional means.

The Business Unit and AML Compliance must maintain records of all Unusual Activity Forms (UAFs) and supporting documentation for five years after the date

Display bullet points in progressive disclosure format.

Display below image with text.

36


State Street


when the account was closed or longer, if required by local regulations.

TranscriptNAInteractivities NACourse Navigation Previous < 15 Next > 17

37


State Street



Lesson Name:

Slide Name:

Screen No: 17

On-Screen Text Graphics DescriptionCDD is the second component of the KYC program and it focuses on assessing the AML and Sanctions risks associated with the customer and other relevant associated and controlling parties.

To get familiar with CDD, please proceed to Module 3: Customer Due Diligence.

Display KYC logo with the text.

Highlight the CDD logo. TranscriptNAInteractivitiesNACourse NavigationPrevious < 16 Next > NA

38
