The MAS Guidelines to Notice 626 on Prevention of Money Laundering and Countering the Financing of Terrorism outline controls that must be implemented to mitigate the risks associated with money laundering/terrorism financing.
Identify a specific MAS regulatory requirement, other than that in Q1, for a firm in a regulated financial services sector with which you are familiar. Prepare a note for the head of compliance which:
highlights the requirement’s objective
identifies the business unit(s)/activity the requirement primarily affects
comments on the measures that need to be taken to achieve the objective.
The term ‘three lines of defense is often used. Explain the term ‘three lines of defense as it relates to the management of compliance risks.
You have received the results of a recent internal audit. The audit team has advised that they discovered a significant failing in the firm’s onboarding process. Specifically, they have stated that the firm’s current practices in identifying and verifying politically exposed persons (PEPs) are not robust. They highlight a number of cases where PEPs were not identified as such and were onboarded and assigned a standard due diligence rating. Your tasks are to:
a) outline the key regulatory requirement(s) that are not being met
b) in light of your answer to a) above, draft a short paragraph for distribution to all relevant staff outlining what action(s) they need to take
c) prepare a short paragraph for inclusion in the overall report to the board of directors that identifies what corrective action/additional controls will be put in place to address the issue.
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