Through your industry contacts you are aware that, during its recent inspection visits, the MAS appears to have been focussing on how firms effectively deal with the onboarding of high-risk customers. Having shared this perspective in your firm you have been asked to prepare a paper for the senior management to reassure them that, should the MAS visit your firm, there would be no adverse issues if they were to focus on this area. Produce a high-level note that sets out the onboarding process for high-risk customers.
The onboarding function has recently been audited by the internal audit team. Their report has identified a number of weaknesses. They have identified two cases of customers who have been onboarded and incorrectly assigned standards due to diligence ratings.
Identify the failings in each case and propose an amendment to the policies or procedures that you believe would improve future performance in these areas. Your review should cover any escalation process that would be required.
The issues you have discovered in Q2 have caused significant concern that the onboarding process is not functioning correctly in that the firm is failing to identify evident high-risk issues and manage them appropriately. The new Compliance Plan states that this area will be reviewed in quarter four next year. Write a proposal to support the view that this issue cannot wait until the end of next year and which calls for the immediate implementation of new periodic monitoring and reviewing processes for determining risks, rectifying the onboarding issues, and dealing with customer retention.
Your firm operates in multiple jurisdictions, with Singapore as its head office. Produce a note to all heads of compliance that outline the processes required within their regions to ensure adherence to the Group Anti Money Laundering, Countering the Financing of Terrorism, and Proliferation Financing requirements.
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