MAS Updates
MAS Notice 3001
(g) an investment vehicle where the managers are financial institutions -
(i) supervised by the Authority; or
(ii) incorporated or established outside Singapore but are subject to and supervised for compliance with AML/CFT requirements consistent with standards set by the FATF, unless the licensee suspects that the relevant business transaction is connected with money laundering or terrorist financing.
4.18 For the purposes of paragraphs 4.17(f) and 4.17(g)(ii), a licensee shall document the basis for its determination that the requirements in those paragraphs have been duly met.
(V) Review of relevant business transactions
4.19 Where a licensee enters into one or more relevant business transactions with a customer, the licensee shall review the earlier transactions undertaken by that customer to ensure that the current transaction is consistent with the licens ee’s knowledge of the customer.
4.20 A licensee shall pay special attention to all complex or unusually large relevant business transactions or unusual patterns of transactions that have no apparent or visible economic or lawful purpose.
4.21 A licensee shall, to the extent possible, inquire into the background and purpose of such relevant business transactions in paragraph 4.20 and document their findings with a view to making this information available to the relevant competent authorities should the need arise.
