MAS conducted an industry-wide survey of CFT-related controls, and followed up with a series of thematic reviews to assess FIs’ TF risk understanding and examine the effectiveness of their CFT-related controls. This paper sets out MAS’ key observations, and highlights our supervisory expectations that FIs should review against their own controls.
FIs should benchmark themselves against the practices and supervisory expectations set out in this paper in a risk-based and proportionate manner, and conduct a gap analysis. In doing so, FIs should give due regard to the risk profile of their business activities and customers. Where FIs observe any gaps in their frameworks and controls, specific remediation/enhancement measures should be identified and implemented in a timely manner.