With a dedicated department and continuing enforcement, combating money laundering and terrorist financing is clearly front of mind for MAS. The Regulator in Singapore has also worked with the private sector to establish the AML/CFT Industry Partnership (ACIP). And in 2018, ACIP produced three best practice papers on the subject. This trend is likely to continue as MAS conducts more AML/CFT focused inspections on financial institutions.
MAS’s stated focus areas for 2018 are likely to remain a priority and should be a part of your AML/CFT planning:
- Misuse of Legal Persons
- Trade Based Money Laundering
- Proliferation Financing
- Transaction Monitoring Controls
- Board and Senior Management oversight
- Enterprise Wide Risk Assessment (EWRA)
- Tax as a predicate money laundering offence.
Staying on top of AML/CFT
- Understanding your customer: In particular, pay closer attention to customers with complex structures
- Gap analysis: Conduct a gap analysis of your current policies and procedures against the guidance papers released by MAS
- Enterprise Wide Risk Assessment (EWRA): Put in place an EWRA to understand the AML/CFT risks associated with your business. Remember this is a MAS requirement
- Compliance culture: MAS expect the board of directors and senior management to take responsibility for compliance with AML/CFT laws, regulations and guidelines. They should set the tone from the top and embed a culture of compliance throughout the organisation
- Tax risk: Be alert to the possibility of tax-related money laundering especially as more countries adopt Common Reporting Standards.
How can Bovill help?
As MAS continues to focus on AML/CFT and penalises financial institutions who don’t comply with regulation, any successful financial crime prevention programme must go beyond a tick box exercise.
MAS expects firms to adopt best practices where suitable, so we strongly advise you re-evaluate your programme in conjunction with the guidance papers released.
Whether you’re newly licensed or have been around for a while, we can help you make sure that your financial crime prevention framework is fit-for-purpose and meets both the letter and spirit of the requirements. We can:
- conduct AML/KYC customer file testing to ensure it meets MAS’ expectations
- prepare or review your policies and procedures to identify any areas for improvement
- work with you to put in place your EWRA to identify all risks, and set out practical ways to mitigate them
- provide AML/CFT training to your staff – with a focus on the risks associated with the nature of your business.