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Effective AML/CFT Controls in Private Banking

Effective AML/CFT Controls in Private BankingStrengthening AML/CFT Controls in Private Banking Giventheclientattributes,sizeoftransacti onsandcomplexityinvolved,PrivateBanks(PB s)haveinherentlyhigherexposuretomoneylau nderingandterrorismfinancing( ML/TF )risks, , ,elaboratesonsoundpracticesobserved,ands upplementstheMAS :ThispapersetsoutMAS ,andisderivedfromMAS , Control Areas for Improvement1. Corroborating Customers Source of Wealth and Funds Enhancing ControlsStrengthen Detection Improve Oversight32. Detecting and Mitigating Tax-related ML Risks3. Detecting and inquiring into Commercial/Third-party transactional flows4. Exercising Active Senior Management Oversight5. Instituting Sound Performance Management Framework to foster Strong Risk CultureIntroduction1. Source of Wealth and Funds Corroboration2. Effective Tax Risk Management3.

areas of foreign tax evasion and corruption. PBs need to remain vigilant to these risks and implement robust controls at key stages of the account lifecycle, including at on-boarding and ongoing monitoring. The MAS conducted a series of inspections of PBs from 2019 to 2020.

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