MAS conducted a series of AML/CFT inspections that examined the effectiveness of the AML/CFT frameworks and controls of capital markets intermediaries“Capital markets intermediaries” used in the guidance paper includes capital markets services licensees and licensed trust companies. (“CMIs”). This guidance paper sets out MAS’ supervisory expectations of sound practices for CMIs. Further context can be found in the illustrative examples taken from MAS’ onsite findings and recommendations to the inspected CMIs.

While this paper is premised on the inspections of CMIs, the takeaways are applicable and relevant to other types of financial institutions (“FIs”), with the appropriate calibrations. All FIs should therefore incorporate learning points from this guidance paper. FIs should also note that the findings and examples highlighted in this paper are non-exhaustive, and FIs should continue to implement appropriate AML/CFT controls that are commensurate with the nature and complexity of its business.