INTHEBLACK June/July 2024 - Magazine - Page 21
also be required to implement group-wide
AML/CTF policies for their branches and
subsidiaries in Singapore or elsewhere to
have a group policy for mitigating their
AML/CTF risks.
The legislation will introduce a fine
of up to SGD$100,000 (A$111,320) on
directors, owners or partners of CSPs for
breaches of AML/CTF obligations.
Singapore will also form an interministerial committee to prevent corporate
structures from abuse by money launderers,
to enhance controls by financial institutions,
and to centralise and strengthen capabilities
across government agencies to better detect
suspicious activities.
HONG KONG LARGELY COMPLIANT
In early 2023, the FATF issued its first
regular follow-up report on Hong Kong’s
compliance with the FATF’s AML/CTF
recommendations, concluding it was
“largely compliant”.
Hong Kong has recently implemented
risk-based AML/CTF supervision for
most Designated Non-Financial Business
or Profession (DNFBP) sectors, including
accountants, real estate agents and trust and
company service providers.
Hong Kong’s requirements cover three
main areas: suspicious transaction reporting,
monitoring clients and their owners against
designated sanctions lists of entities and
persons, and client due diligence (CDD).
“The first two are not that onerous to
comply with,” says RSM Hong Kong partner
Gary Stevenson, who is the head of IFRS
and independence in the firm’s technical
department. “The CDD is limited to specified
transactions or trust and company secretarial
services. Audit is generally not considered
a specified transaction.
“Larger firms generally do not provide
trust and company secretarial services as part
of their audit business. This will generally be
a separate business unit or they may not do
it. For the smallest firms, there may be no
separation. The smaller end of the market
has probably been affected more.”
The Hong Kong Institute of Certified
Public Accountants (HKICPA) published
AML/CTF guidelines, sample AML/CTF
policies, templates and FAQs after the local
legislation was enacted.
“Many, if not most, small and mediumsized audit firms adopted these materials
and they were very helpful,” Stevenson says.
“Larger firms already had more sophisticated
AML/CTF policies and procedures in place
to satisfy the requirements of their global
accounting networks.
“Overall, the sector appears to have
received the new AML/CTF regime well.
It is simply part of the client acceptance
or reacceptance process now.”
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