On 28 October, the Monetary Authority of Singapore (MAS) issued circulars to fund management companies, licensed trust companies, corporate finance firms, broker dealers, insurance brokers and financial advisers highlighting various internal controls that firms should implement.
The circulars summarized the good and bad practices of almost 300 firms identified during recent thematic inspections relating to anti-money laundering/countering terrorist financing (AML/CTF) measures and business conduct.
Why should you know about it?
Firms should familiarize themselves with the MAS’ circulars and assess that they have implemented the internal controls and new AML/CTF obligations to the standards required.
Those include taking adequate AML/CTF measures, timely depositing of customer monies into specified accounts, implementing employee personal account dealing policies to mitigate conflicts of interest and robust post-trade monitoring to detect trading irregularities.
Implementation of AML/CTF obligations
The circulars also contain useful guidance on the correct implementation of AML/CTF obligations as well as on some new measures that the MAS has recently introduced. Firms should:
- Perform ongoing monitoring of customer relationships.
- Comply with the requisite frequency for employee training.
- Perform timely and adequate customer due diligence. Fund management companies were reminded that before April 2015, their definition of customers includes underlying investors into unlisted investment vehicles that they managed. Licensed trust companies were reminded to verify the identity of the protector of the trust and effective controller of the settlor.
- Conduct checks of any service provider to whom Customer due diligence was outsourced to.