Late October
the MAS issued a paper on ‘ENHANCING ANTI-MONEY LAUNDERING & COUNTERING THE
FINANCING OF TERRORISM MEASURES AND CONDUCT’ following inspections of 300 FI’s
done between September 2014 and January 2015 < http://www.mas.gov.sg/~/media/MAS/Regulations%20and%20Financial%20Stability/Regulations%20Guidance%20and%20Licensing/Financial%20Advisers/Circulars/CMI%20052015%20Circular%20to%20financial%20advisers%20on%20enhancing%20AMLCFT%20measures%20and%20business%20conduct.pdf
>
Not
surprisingly quite a number of issues were found; let’s look at some of the key
topics mentioned. Ongoing monitoring of business relations is a key finding as
well as the (lack of) frequency of training on AML/CFT. Furthermore, it was
found that policies and procedures were not always properly formalized and not
applied consistently.
Moreover, it
was found that in respect of Identification and Verification not all
obligations were always met, that risk assessment criteria were often not
formalized and shortcomings in the screening of relevant persons were found.
Other observations mention the absence of formal Service Level Agreements in
outsourcing scenario’s and the lack of Quality Assurance around AML/CFT
processes.
No real
surprises here unfortunately; from our own experience we can concur with the
findings. The clients that we work with have all made substantial progress in
improving their AML/CFT framework, yet there always continues to be room for
improvement. Some key areas that we see from our own perspective at i-KYC
include the following:
- formalization of policies and procedures –
not only need policies be documented, they also need to be clear to all staff
and they need to be embedded in day-to-day processes and procedures;
- training, training and more training
throughout the organization; at all levels and on all policies;
- consistency in operational execution,
supported by a quality assurance framework.
Many FIs
still see AML/CFT measures as a burden hence the shortcomings found. For us Integrity
Means Business and that implies we ensure policies are adhered to while the
organization runs as efficient and effective as possible. That is the real
challenge.
