May 8, 2022

MAS recently published this report < https://www.mas.gov.sg/-/media/MAS-Media-Library/publications/monographs-or-information-paper/IMD/2022/Strengthening-AML-CFT-Name-Screening-Practices.pdf > which highlights and summarizes their findings on name screening practices of selected FIs in Singapore.

The findings are not dramatic, good practices do exist and many FIs have SOPs in place, but there seems to be a lot of room for improvement as well. The report mentions an ‘uneven robustness’ of the screening framework and processes, indicating that some FIs mastered the discipline but (many) others are struggling with name screening.

Two points from the report are worth mentioning:

  1. Several financial institutions are reported to lack senior management oversight
  2. Many financial institutions rely heavily on their system vendors with regards to settings, parameters and interpretation of screening results.

Most of these observations coincide with what we see in our daily practice working with our clients across the globe. There’s a big difference though….

In our practise we always look at FEC compliance from 3 angles: good, cheap and fast. We help our clients meet the regulations and support them to ensure all compliance processes are done to the agreed quality levels as stipulated by MAS and other regulators.

In addition though, we also look at the other 2 dimensions: costs and speed. Where speed usually relates (in)directly to customer impact. Doing it right can come at a cost and might impact customers. These are not of primary interest to regulators but they should be for financial institutions.

So if you or your organization struggles with name screening or if you just want a high level risk assessment, some assurance or a thorough review, don’t hesitate to contact us.

Rolf van der Pol