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?


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.

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.

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 -

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Friday, 6 May 2022

Observations from the MAS on namescreening practises in midsized and small FIs


MAS recently published this report < > which hightlights and summarizes their findings on namescreening practises of selected FIs in Singapore.

The  findings are not dramatic, good practises do exist and many FIs have SOPs in place, but there seems to be a lot of room for improvement as well. The report mentions an ‘uneven robustness’ of the screening framework and processes, indicating that some FIs mastered the discipline but (many) others are struggling with namescreening.

Two points from the report are worth mentioning:

1.       Several financial institutions are reported to lack senior management oversight

2.       Many financial institutions rely heavily on their system vendors with regards to settings, parameters and interpretation of screening results.

Most of these observations coincide with what we see in our daily practise working with our clients across the globe. There’s a big difference though….

In our practise we always look at FEC compliance from 3 angles: good, cheap and fast. We help our clients meet the regulations and support them to ensure all compliance processes are done to the agreed quality levels as stipulated by MAS and other regulators.

In addition though, we also look at the other 2 dimensions: costs and speed. Where speed usually relates (in)directly to customer impact. Doing it right can come at a cost and might impact customers. These are not of primary interest to regulators but they should be for financial institutions.


So if you or your organization struggles with name screening or if you just want a high level risk assessment, some assurance or a thorough review, don’t hesitate to contact us.


Rolf van der Pol



Thursday, 26 September 2019

The KYC utility revisited – is a problem shared indeed a problem halved?

KYC or better Customer Due Diligence and the related work of Transaction Monitoring are often considered cumbersome and painful. Not to mention that financial institutions can be fined heavily for not getting it right.
The idea of a KYC utility - shared amongst FIs - keeps popping up, recently in The Netherlands and the Nordics ( and not that long ago in Singapore (we wrote earlier about that here
Despite the failures and the initiatives that don’t get any further than the drawing table, many FIs and regulators still think it’s worth a try. Let’s have a look at the possible reasons and success factors.

A KYC utility makes sense
FIs in the same jurisdiction need to adhere to the same regulations and even though internal controls, systems, risk appetite and policies might differ, likely a lot of the work is similar if not the same. That might mean a duplication of work so cost savings are possible.
Money launderers don’t do all transactions with one bank; what looks perfectly acceptable to one FI might not be so acceptable if the transaction behaviour is viewed across all the banks that the client is using. By nature, the knowledge on a client will improve if banks can see all the clients’ activities across organisational boundaries.
Everyone who has dealt with onboarding of clients will have heard the comment “Why do I need to provide that documentation? Bank ABC doesn’t require that either.” Aligning onboarding requirements and shared CDD will increase the speed of onboarding and increase customer satisfaction.

There are plenty examples of off-shored centres, external companies and internal service centres that have proven that processes and policies across jurisdictions can be serviced in and by one and the same team. There are no inherent reasons that make a KYC utility impossible to realise.
It can be done, we’ve seen it working, we’ve managed these service centres. It all comes down to the (political) will to make the KYC utility a success, the ability to overcome differences in the participating FIs and the power to execute in the utility itself.

find the original article and find other stories here