The circular highlights that wealth management firms have inherently higher exposures to ML/TF risks due to factors including its client attributes, transaction size and complexity, and as a result, should:
- Strengthen Board and Senior Management [BSM] oversight and risk and control functions;
- Conduct added review and quality assurance testing regarding the identification of higher risk customers, source of wealth, and source of funds in high growth areas;
- Continue to exercise vigilance over higher risk customers and transactions.
Wealth management firms with operations in Singapore should read the MAS circular and enact MAS’s recommendations.