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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