This Circular sets out MAS’ key observations and supervisory expectations for effective AML/CFT frameworks and controls that VCCs and their appointed EFIs should note.
Notice VCC-N01 Prevention of Money Laundering and Countering the Financing of Terrorism – Variable Capital Companies (VCCs)
VCCs are required to put in place robust controls to detect and deter the flow of illicit funds through Singapore's financial system.
Such controls include the need for VCCs to identify and know their customers (including beneficial owners), conduct regular account reviews, and monitor and report any suspicious transactions promptly. VCCs are required to appoint an eligible financial institution (EFI) to conduct the necessary checks and perform the measures to enable the VCC to comply with its AML/CFT requirements.
The AML/CFT requirements for VCCs can be found in this Notice, which include having internal policies and implementation of controls relating to:
- Conducting risk assessment and risk mitigation
- Customer due diligence, including maintaining a register of beneficial owners
- Reliance on third parties by the VCC’s EFI
- Record keeping
- Suspicious transaction reporting