1 Inad of documentation on Suspicious Transaction Reporting (“STR”) and Third Party Authorisation procedures SFA 04-N02: According to one All TRs will have gone through AML Para 4 (Customer Due remisier, most of which covers CDD and the Diligence); and the time, he will consequences of any breaches of Para 5 (Simplified open accounts AML/CFT Regulations. BD had clarified Customer Due Diligence) for clients first with the remisiers. They are aware of Para 6 (Enhanced before verifying their responsibility to perform Customer Due Diligence) them verification before accepting the Para 9 (Suspicious Another applicant as client by signing on the Transactions Reporting) remisier informed application form. that for Guidelines to SFA04-N02, account When interviewed by Compliance paragraph 4 to 67 openings, he will colleagues, their responses were in still indicate on relation to the accounts that were opened MAS Circular CMI 01/2013 the account by applicants, who are mainly existing (Controls Over opening clients or referred by existing clients, in Correspondence Addresses of documents that persons via PIC. Customers) he had performed As the remisiers were not present at the time of submission of the application forms, verification. remisiers will endorse on the top right hand Thereafter, he corner to indicate their acceptance of these will call up the forms. It is understood that the remisiers client for are aware of most of these applications verification. beforehand. For those cases that they
1 Inad of documentation on Suspicious Transaction Reporting (“STR”) and Third Party Authorisation procedures SFA 04-N02: Para 4 (Customer Due Diligence); and Para 5 (Simplified Customer Due Diligence) Para 6 (Enhanced Customer Due Diligence) Para 9 (Suspicious Transactions Reporting) Guidelines to SFA04-N02, paragraph 4 to 67 MAS Circular CMI 01/2013 (Controls Over Correspondence Addresses of Customers) According to one remisier, most of the time, he will open accounts for clients first before verifying them Another remisier informed that for account openings, he will still indicate on the account opening documents that he had performed verification. Thereafter, he will call up the client for verification. All TRs will have gone through AML which covers CDD and the consequences of any breaches of AML/CFT Regulations. BD had clarified with the remisiers. They are aware of their responsibility to perform verification before accepting the applicant as client by signing on the application form. When interviewed by Compliance colleagues, their responses were in relation to the accounts that were opened by applicants, who are mainly existing clients or referred by existing clients, in persons via PIC. As the remisiers were not present at the time of submission of the application forms, remisiers will endorse on the top right hand corner to indicate their acceptance of these forms. It is understood that the remisiers are aware of most of these applications beforehand. For those cases that they
Appendix%201%20(Review%20on%20KYC%20of%20Front%20Office%20BUs)%20BD%20Remisier%20and%20BD%20MSF.docx