Regulatory Alerts2020-12-04
Added · Updated
Guidelines to Notice VCC-N01 on Prevention of Money Laundering and Countering the Financing of Terrorism – Variable Capital Companies
These guidelines provide guidance to variable capital companies (VCCs) on complying with MAS Notice VCC-N01 regarding the prevention of money laundering and countering the financing of terrorism. VCCs are required to engage a single eligible financial institution (EFI) to conduct necessary checks and perform measures on their behalf, while the VCC remains ultimately responsible for its AML/CFT obligations and must maintain oversight of the EFI's activities. The document clarifies definitions for connected parties, customers, legal arrangements, and legal persons, and outlines specific customer due diligence approaches for scenarios involving distributors and re-domiciled entities. It further mandates that VCCs conduct holistic ML/TF risk assessments approved by their board, considering factors such as customer profiles, jurisdictions, and product complexity, and implement governance structures including the three lines of defence model.