29 September 2020
On 4 September 2020, the Monetary Authority of Singapore (“MAS”) issued a guidance paper setting out its supervisory expectations of effective Anti-Money Laundering/Combating the Financing of Terrorism (“AML/CFT”) controls in the private banking industry, including illustrative examples taken from MAS’ inspections of private banks (“PBs”) (“guidance paper”). The guidance paper supplements the MAS Guidance on Private Banking Controls issued in 2014.
The guidance sets out the following five key control areas for improvement:
- Corroborating customer’s source of wealth and funds
- Detecting and mitigating tax-related money laundering risks
- Detecting and inquiring into commercial/third-party transactional flows
- Exercising active senior management oversight
- Instituting sound performance management framework to foster strong risk culture
While this guidance paper is derived from the inspections of PBs, the takeaways are applicable and relevant to other types of financial institutions (“FIs”), with the appropriate calibrations. MAS states that all FIs should study and incorporate learning points from this guidance paper in a risk-based and proportionate manner. FIs should note that the findings and examples highlighted in the guidance paper are non-exhaustive, and continue to implement appropriate AML/CFT controls that are commensurate with the nature and complexity of their business.
The following materials are available on the MAS website www.mas.gov.sg:
- MAS webpage: Effective AML/CFT controls in private banking
- MAS guidance paper: Effective AML/CFT controls in private banking
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