Thursday 28 December 2023

Singapore as tax haven

 

This article is a week old and I’ve been pondering what to think and make of it. It’s always good news if perpetrators are caught, but something just feels amiss here.

I’ve worked for and with financial institutions most of my working life and I’ve tried to do what’s right for the institution I worked for, its customers and society at large. But even when I had senior positions, I was never acting on my own. I was an employee, firmly embedded in organisation structures, reporting lines, policies, procedures, controls and all these other things that employees in an organisation deal with.  

Yet this article only briefly mentions the organisation the person worked for and it looks like it’s something done by an individual on his own. While MAS and other regulators indeed also include the individual responsibility and accountability of employees, every regulatory framework I know is built around what a Financial Institution as a whole needs to do.

Maybe I’m missing something but it would seem logical that the institution that this person was working for would be under scrutiny in the first place. Instead of making it look like an individual acting completely in isolation.

Any thoughts? Am I missing something here?

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Monday 4 December 2023

KYC – Know Your Customer is not only relevant for banks

We’ve talked about it before but this article https://www.straitstimes.com/singapore/courts-crime/jail-for-2-nominee-directors-whose-shell-companies-laundered-almost-20m-in-scam-profits highlights the point again. Money launderers will go to the weakest link into the financial system and if that is a bank, great they will go there, but if banks have strengthened their #AML and #CFT controls and have sound #FCC Financial Crime Compliance processes in place, criminals will look for other points of entry into the financial system.

They will use corporate service providers, lawyers, real estate agents, suppliers of luxury goods, yacht brokers and car dealers to help them clean the dirty proceeds of crime.

So it’s only a matter of time for regulators to step in and strengthen regulations and controls over non-FIs. Be prepared and train your organisation. 

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Monday 13 November 2023

A candid – although short – interview with outgoing MAS MD Ravi Menon on money laundering

 A candid – although short – interview with outgoing MAS MD Ravi Menon on money laundering https://www.bloomberg.com/news/videos/2023-11-02/singapore-central-bank-on-battling-money-laundering-video

Some key points we picked up:

-          on the question ‘is this just the tip of the iceberg’ his answer is not conclusive – but I believe the consensus in the market would be that with so much money flowing into Singapore there must be more going on – happy to hear opposing views though….

-          Menon talks about that when ‘dirt is found in the house it needs to be cleaned’ – yes, it needs to be cleaned and thoroughly at that, but no mention is made of additional measures of prevention

-          interesting as well that – finally – it is recognised that the real estate sector (and other luxury segments in the economy) need to do more in the fight against money laundering.

Regulators focus – of course – on regulations. But it’s not just policy and guidelines that fight financial crime. Much more it is the operational practises in financial and non-financial institutions that stop criminals entering the financial system. Only then can an organisation achieve operational compliance. And it all starts with training and awareness…

 

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Monday 18 September 2023

What is the MAS up to

 

The news about the capture of close to a billion Singapore dollar in assets under a suspicion of money laundering is only the beginning…

-          first there’s a reaction from MAS in the Business Times 

-          the MAS is pushing banks to probe harder to prevent ML read more here  

At the same time there are many doubts about the whole saga among others:

-        how could these foreigners acquire landed property (that’s a very stringent process in Singapore  as mentioned by Singaporelawwatch

-         why MAS is not more stringent towards real estate agents, car dealers and jewellers?

 

any thoughts?

 

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Wednesday 30 August 2023

Don't be impressed by wealth

 

Nice work CNA this article – the experts know what money laundering is but many people don’t and general awareness needs to improve. Netflix series like Ozark or a movie like The Laundromat have perhaps raised awareness on money laundering, but wealth and the flaunting thereof still raises more often awe than suspicion.

Most people don’t realise that there are always serious crimes behind the money to be laundered. It’s called dirty money for a reason. These crimes can involve corruption, trading drugs or endangered species, tax evasion or human trafficking and slavery; things no reasonable and respectable person should be involved in.

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Tuesday 22 August 2023

AML in real estate


We all know that criminals – and perhaps people in general – will look for easy ways to achieve their goals - so it’s likely that a money launderer will not bring it’s dirty money to a bank known for strict KYC policies and tight AML controls. Also the recent case in Singapore where 1 billion in assets was confiscated indicates that criminals look for an easy way into the financial system and often that  entrance sits with real estate companies or luxury goods dealers, not with traditional banks.

It's therefore a good sign that both in the US and in Australia new laws and regulations are on the way… fighting financial crime needs to happen across all entry points, all financial institutions and all businesses that accept money from people they don’t know well enough… KYC, knowing your customer is still key in all aspects of business.

 

 

https://www.reuters.com/world/us/us-set-unveil-long-awaited-crackdown-real-estate-money-laundering-2023-08-10/

https://arctic-intelligence.com/insights/blog/close-money-laundering-loopholes-in-australias-real-estate-sector?utm_source=Social+Media&utm_medium=Linked+In&utm_campaign=Blogs

Monday 7 August 2023

The importance of training in achieving operational financial crime compliance

We can't repeat it often enough. Awareness of #financialcrime, risks and #compliance can only be built with continuous #training and #management #attention. Listen to this episode on the Fincircle podcast to Pieter Ris on how we help #banks - and #FIs in general - achieve operational compliance in the fields of #amlcft #kyc #cdd and other areas of preventing financial crime Fincircle - e-learning.


Tuesday 1 August 2023

The MAS in Singapore on Family Offices

 The MAS in Singapore is - almost like a commercial organisation - advertising the country as a financial hub and welcoming Family Offices as this statement shows:

“As an established financial hub, Singapore will continue to grow opportunities for wealth management and support the evolving needs of family offices…we also believe that the best legacy that those with greater means can leave behind is a positive impact on society.”

Indeed the best legacy the wealthy can leave is a positive impact on society. Question is of course if that purpose is not better served by taxing the wealthy and have governments decide on what’s best for society…

More can be read here - https://www.mas.gov.sg/development/wealth-management

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