The document sets out MAS’ supervisory expectations for external asset managers in 5 areas, namely Governance, Risk Assessment Framework, Customer Due Diligence (CDD), Enhanced CDD, and Suspicious Transactions Reporting.
This should trigger some initial thoughts such as:
- Does my governance structure provide adequate oversight, inculcate appropriate risk culture, implement 3 lines of defense and has sufficient compliance resources?
- Do I have risk framework in place and implement enterprise wide risk assessment and conduct initial and ongoing client due diligence (CDD) especially for higher risk profiles?
- Do I have processes in place to identify and monitor suspicious transactions and report to the authorities?
Below is a summary of some of the key takeaways in the information paper. For the full details, please refer to the MAS website https://www.mas.gov.sg/publications/monographs-or-information-paper/2022/strengthening-amlcft-practices-for-external-asset-managers
Disclaimer: The information, views or opinions expressed are provided for general information and should not be relied upon as legal or professional advice.