KYC Introduction Flashcards
Platforms Operating Model - what are the two types of platforms?
Client platforms - owning profit and loss for external client services
Enterprise platforms - driving accountability for internal services
What are the cross functional teams in the Platforms Operating Model?
- Pods - product oriented delivery teams - operate with agility, delivering work through efficient sprints.
(Can be diverse, such as Product owners, Data Scientists, product owner, process engineer, software engineer) - SDGS - skills service Delivery Groups - accountable for a common deliverable performing activities that are consistent with a discipline to reduce variability.
What are the benefits of a Platforms Operating Model?
The benefits of this model are immense for employees and empowers creativity and autonomy, reduces duplicative processes, and provides new growth opportunities.
For clients it facilities a seamless digital experience, leveraging the power of data to anticipate unmet needs.
It empowers our culture by breaking down silos and prioritizing resilience.
BNY is a US company which falls under the Bank Secrecy Act (BSA) - these regulations are like (WHO’s?) recommendations that form our KYC program.
Financial Action Task Force (FATF) -
Provide guidance that forms the regulatory framework to combat money-laundering and terrorist financing
Financial institutions are required to have an AML Policy
The KYC teams work closely with the LOBs and Lead KYCO / CROs to ensure KYC is completed
Each customer must be assigned to a LOB (Line Of Business).
The EOP (Enterprise Onboarding Platform) works with most LOBs, however there are exceptions non-institutional LOBs.
Each customer has a “Relationship Owner” (Lead KYC Owner) who bears primary responsibility for ensuring that the Company’s overall KYC and AML knowledge is accurate, including all accounts under the relationship.
The Lead KYC Owner will be responsible for completing and certifying the KYC profile is complete at Inception of the customer relationship with BNY and for ongoing monitoring requirements (Periodic Reviews) as outlined in the Policy and Manual throughout the course of the Company’s relationship with that customer
What are the Lines of Business (LOBs) supported by KYC teams?
CT / TS / CCM / GCM / AS / AIS / DR / Pershing / ???
CT = Corporate Trust
TS = Treasurey Services
CCM = Clearance & Cash Management
GCM = Global Client Management
AS = Asset Servicing
AIS = Alternative Investment Services
DR = Depository Receipts
Pershing (Intermediaries / End Investors)
Markets
Name 6x Key Roles of the KYC process
Lead KYC Owner (LKYCO)
KYC Analyst - (New Business or Periodic Review)
CRO delegate - Client Relationship Officer
QC Analyst - Quality Control
QSS Analyst - Query Static & Screening - (escalates to LKYCO)
FCCO - Financial Crimes Compliance Officer - Reviews PEPs & high risk profiles
What are the 5x Enhanced Standards Requirements?
Customer Identification Program
Customer Due Diligence
Products and Services
Local Requirements
Beneficial Owners & Related Parties
New Business - the LOB will complete the New Business Intake Form to notify of a new client.
What’s the next steps for a KYC NB Analyst?
The KYC NB Analyst will review the information provided and complete KYC requirements in collaboration with Lead KYCO /Business Line.
Must pass QC approval + business line approvals
Periodic Review - Review & refresh the information on the client profile. The frequency of this review is dependent upon risk rating.
What are the Risk Ratings & who does the KYC PR Analyst collaborate with?
Risk Ratings:
Low - 5 years
Medium - 3 years
High - 1 year
KYC PR Analyst will collaborate with Lead KYC Owner and/or Client to complete review.
Must pass QC approval+ business line approvals
Query Static Scanning - what do they review?
Review Sanctions and WorldCheck alerts produced in Bridger/LexisNexis application during regular batch scanning and/or at review and escalate to business/ Compliance, as necessary.
They are also point of escalation for negative news for the Adverse Media Search process
Account Activity Review (ARR) team - what do they review?
This team reviews the customer’s transactions and other account activity to ensure no suspicions of Money Laundering/Fraud, for specific high risk customers and all high risk products over a 12 month period.
Quality Control?
Provides 4-eye review of every customer’s KYC profile to ensure KYC requirements are satisfied as outlined in latest AML/KYC Policy - at on-board and Periodic Review
KYC Support Team - what activities do they work to assist EOP
5AMLD/UBO Discrepancy Reporting
US PAC Update
Banking licence update
Scheduling & Business Connect
LUX ASL addition/deletion/update
CID maintenance - (Merger, Reaffiliation, name change, note holder addition, address update)
Population Management
Central Offboarding Team
Clients will be offboarded who are delinquent from fulfilling KYC Requirements, who have requested to terminate relationship with BNY, or who the business have decided to Offboard.
The Offboard team will receive exit requests, perform preliminary checks, and syndicate the KYC ownership transfer between LOBs as relevant.
Ensure client fully vetted across all LOBs before client marked for exit and KYC is put on hold
