Question 1

You are the compliance officer for a financial institution situated and regulated in Singapore, whose parent company is based in New York. The rate of growth of the firm you work for has been falling in recent years. The head office has therefore sent one of the senior sales directors to your office, with a mandate to increase sales. The sales director has reviewed your current product offerings and decided that the firm needs to introduce some new investment products. The first proposal is to launch a product that would be regarded as a
very complex investment product and this deviates from the usual, more straightforward, products the company has historically offered. You have been assigned to assist the sales director and you initially advise him that the proposal brings significant new risks and challenges.

The sales director wants to understand the issues and has asked you to provide a note that:

• Identifies the risks of distributing a complex financial product in Singapore.
• assuming the risks associated with this new product launch are understood and the firm decides to continue with the launch, takes each of the points you have identified in a) above and:

i. Identify the stakeholder responsible for dealing with the issues stakeholders will include, for example, legal, compliance, risk, audit, sales, and relationship managers
ii. Describes how you will inform the various stakeholders of their  responsibilities and the activities required of them in applying the risk management processes
iii. Notes the specific risks and the risk-mitigation strategies and associated
controls that you suggest the various stakeholders should implement
iv. Describe how you will test and monitor the various stages involved in the
launch.

Question 2

You have recently joined a regulated firm in Singapore. The head of compliance initially asked you to review the firm’s suspicious transaction reporting policies and procedures. You have uncovered a number of areas of concern that need to be addressed.

a) A review of the limited internal STRs submitted by staff found that all required significant follow-up since they omit significant details. Clearly, the staff needs better guidance about the type of information that they should be provided to facilitate the investigations of the money laundering reporting officer and perhaps, subsequently, law enforcement. Produce an internal STR form that may be used to guide staff to provide complete information.
b) It is also evident that the requirements for onward reporting of an internal STR to the Suspicious Transaction Reporting Office are not clearly understood. Identify the specific regulatory reporting requirements for your financial institution and articulate them in a note to the head of compliance.
c) i. Currently the guidance to staff states that they must report any suspicions of money laundering or terrorist financing ‘only when they are confident that criminal activity is taking place. Produce a revised version of this specific part of the policy to help staff by describing their responsibility more accurately.
ii. The current guidance also states that staff must report any suspicion ‘as soon as reasonably practicable. Articulate a procedure that sets out timelines for staff to deal with suspicious activity, with the objective of enabling the money laundering reporting officer to ensure that the regulatory reporting timelines are met.
d) The head of compliance agrees with both your proposals under c) above. She asks what procedures do you plan to implement to monitor how well staff complies with the new requirements, so that you may monitor the success rate and any resource requirements. Outline your recommended procedures.
e) ‘Advances in technology continue to drive product development and service offerings within the financial services industry. However, we must also be aware of the new or heightened risks they bring and be prepared to combat them.’

Provide an example of a product or service launched in recent years that has presented new challenges in anti-money laundering and/or countering the financing of terrorism and describe how these challenges were addressed.