The Monetary Authority of Singapore has issued an Information Paper which says that an “enterprise-wide money laundering and terrorism financing risk assessment” (EWRA) assesses a financial institution’s inherent money laundering and terrorism financing risks, the effectiveness of the control environment designed to mitigate those risks, and the need to implement additional measures to manage residual risks where necessary. The requirements and expectations pertaining to EWRA are laid out in MAS Notices and Guidelines.  The information paper sets out MAS’ supervisory expectation of effective EWRA frameworks and processes.  While the paper does not impose new regulatory obligations, it says that financial institutions should study the guidance to identify and address gaps in their EWRA frameworks and processes.  It includes case studies involving flawed EMRA methodology and good use of data.  Informed by reviews of institutions undertaken by MAS, the Paper says that an EWRA provides institutions with an overview of their risk exposure and forms the cornerstone of banks’ AML/CFT risk management.  A robust EWRA enables them to better understand their money laundering and terrorism financing risks, implement relevant policies and control procedures to effectively mitigate these risks, and optimise the allocation of AML/CFT resources.


Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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