What are the AML requirements for Fund Management Companies?
All Fund management companies will comply with MAS requirements on AML/CFT. The AML/CFT requirements for capital markets intermediaries include the following:
• Risk assessment and risk mitigation.
• Customer due diligence.
• Reliance on third parties.
• Correspondent accounts.
• Record keeping.
• Suspicious transaction reporting.
• Internal policies, compliance, audit and training.
The requirements are the same across the different licensed entities.
For the purposes of MAS Notice SFA04-N02 on Anti-Money Laundering, fund management companies fall under the term "Capital Market Intermediaries (CMIs)".