4 MANAGEMENT OVERSIGHT, POLICIES AND TRAINING
relation to AML/CFT should be clearly set out.
The roles and responsibilities of the board of directors and senior management in
4.2 There should be a formalised process in place to keep the board of directors and senior management informed regularly of compliance and risk management efforts, audit reports, identified compliance and risk management deficiencies, and corrective actions taken in relation to AML/CFT. Examples of such reports may include statistics on the number of Suspicious Transaction Reports (“STRs”) filed, sanctions hits, outstanding transaction monitoring alerts and/or sanctions alerts including aging reports and resource issues.
4.3 Senior management are reminded to take prompt corrective actions to ensure the proper and timely remediation of deficiencies in AML/CFT controls and risk management.
4.4 There should be adequate processes in place for updating senior management and any other relevant personnel of AML/CFT-related updates issued by the Authority or other relevant authorities in Singapore. There should also be a designated employee (e.g. Head of Compliance) responsible for providing such updates to management and other relevant personnel.
4.5 There should be a clear and detailed set of documented AML/CFT policies and procedures in place that incorporate, at a minimum, the following elements:
(a) Customer due diligence and screening procedures;
(b) Documentation of screening results;
(c) Assessment, escalation and reporting of suspicious transactions; and
(d) Frequency and recipients of AML/CFT-related training.
4.6 AML/CFT policies and procedures should be reviewed regularly by the board of directors and/or senior management. At a minimum, these policies should be reviewed whenever there are changes in regulations or if there is a significant change in the insurer’s business strategies.
4.7 Regular AML/CFT-related training10 should be conducted for the board of directors, employees and agents (where applicable) of the insurer. Such training may take the form of seminars, e-learning modules, etc.