| University | International Compliance Association(ICA) |
| Subject | Regulatory Compliance |
Question 1.
You and the other staff in the compliance team are about to undergo your annual appraisal with the head of compliance. Ahead of the meeting, the head of compliance has asked all her team to identify any specific MAS regulation relevant to your firm, which is a firm in a regulated financial services sector in Singapore. You are to prepare your note for the head of compliance that highlights the regulation selected, states its objective, identifies the business unit(s) it primarily affects, and comments on the measures that need to be taken to fulfill this requirement. Prepare your notes for submission.
Question 2.
Compliance practitioners often refer to the ‘three lines of defense’. Write a summary explaining the term as it relates to compliance risk management.
Question 3.
Your firm has recently been visited by the Regulator. As part of the debrief, the firm was advised that the front-line staff and the onboarding teams do not seem to understand the need to perform enhanced due diligence measures, including establishing the source of funds (SoF) and source of wealth (SoW), and do not know the difference between them. As a result, the firm’s records for politically exposed persons (PEPs) are invariably deficient in one or both of these areas. Your tasks are to:
a) identify the specific MAS regulation requiring the firm to perform enhanced due diligence and establish SoW and SoF for PEPs
b) in light of your answer to a) above, draft a short paragraph for distribution to all relevant staff which provides them with definitions of SoW and SoF and guidance as to the action(s) they need to take relating to these aspects when onboarding a PEP
c) prepare a short paragraph for inclusion in the overall report to the board of directors that identifies what corrective action/additional controls will be put in place to address the issue.
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