In early 2017, State Street announced a settlement agreement with the US Department of Justice concerning overcharging of six EMEA-based clients for transition management services in 2010 and 2011. The Monitor’s primary responsibility is to assess, oversee, and monitor our compliance with our obligations under the terms of the Deferred Prosecution Agreement (DPA), so as to specifically address and reduce the risk of any recurrence of the misconduct. The Monitor’s oversight program has been designed around four work streams: historical/remediation of prior conduct, review and testing of business units/processes for similar vulnerabilities, assessment of the firm’s Compliance Framework and the Corporate Functions’ effectiveness in said framework and review and analysis of compliance-related initiatives.
The Monitor Liaison is the primary point of contact for the Monitor and his team, and for all State Street employees and entities interacting with the Monitor. This position will report directly to the Monitor Liaison and manage one of the four workstreams identified above. The term of the role is expected to be 3 years. The responsibilities include:
Manages and oversees interaction with the Monitor’s team for completing the plan of work related to the prior misconduct for transition management, indirect FX and the billing of administrative expenses. These responsibilities may include arranging and attending as necessary presentations, interviews and status meetings with the Monitors team.
Prepares interviewees and assist businesses with fulsome, transparent responses
Advises the Business and Functional Units on the appropriateness of document submissions and presentations to the Monitor and his team
With the assistance of Monitor Liaison and Legal, substantively reviews all presentations and manages issues related to Confidential Supervisory Information
Provides guidance and support to the Business and Functional Units for all interaction with regulators and clients regarding the status of the Monitor’s review
Supports the Monitor Liaison to oversee IT processes to ensure that secure mechanisms are in place to provide the Monitor and his team with confidential State Street data
Supports and advises the Business and Functional Units on the responses to the Monitor’s recommendations. Supports the Monitor Liaison on their responsibilities for timely responses prior to final submission to the Department of Justice
Supports the Monitor Liaison to oversees the implementation plans with regard to the Monitor’s recommendations Provides Business and Functional Units with status updates and advice regarding issues and concerns arising in connection with the Monitor review and process