Compliance Insight – May 2023
On 6 April 2023, the Monetary Authority of Singapore (MAS) published updated Guidelines on Licensing, Registration and Conduct of Business for Fund Management Companies (SFA04-G05). These updates namely highlight MAS’ following expectations:
- Fit and proper assessments of new directors, CEOs and representatives should include reference checks with previous employers. If a person is hired to manage a specific investment strategy, the fund management company should also check the person’s track record.
- The fund management company should develop appropriate tools or metrics suitable to the nature, scale, and complexity of the assets and the investment strategies employed for the portfolios it manages to ensure accurate and timely tracking and assessment of risk exposures.
- The fund management company should have clear lines of escalation to keep its board of directors and senior management informed of risk exposures on a continual and timely basis.
- The fund management company should have in place clear policies and procedures to handle customer complaints and feedback effectively and promptly.
- The fund management company should put in place an appropriate governance structure to effectively monitor the conduct of individuals who carry out activities for and on its behalf on an ongoing basis.
- The fund management company should establish plans how to wind down its business or the funds it manages.
Fund management companies (A/I LFMCs and RFMCs) whose financial year coincides with the calendar year should also not forget to submit their annual returns for 2022 by 31 May 2023.
Finally, the MAS just issued the 2023 ML/TF Risk Assessment Survey to be completed by 30 June 2023.
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