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SFC licensing and compliance hints – Apr 2018

Updated AML / CFT self-assessment checklist

The SFC updated its AML / CFT Self-Assessment Checklist on 26 March 2018. It is available here.

AML compliance officers should use this checklist to assess compliance with the key AML / CFT requirements, and report the findings to senior management (e.g. Manager-in-charge for Overall Management Oversight or the Board). Should any deficiencies be identified, they should be rectified immediately.

The SFC mentioned in its circular that “In the course of our regular inspections, we may require LCs and AEs to provide documentary evidence of the performance of [their regular review to monitor AML/CFT compliance] and its results.”

On-site inspections

In the past two weeks, a number of our clients have told us that they are about to be inspected by the SFC. The figures below from the SFC’s website show the frequency of SFC inspections in recent years.

Risk-based, on-site inspections conducted:

Quarter ended 30/6 Quarter ended 31/3 Quarter ended 31/12 Quarter ended 30/9
74
(in 2017)
71
(in 2017)
89
(in 2016)
81
(in 2016)
71
(in 2016)
80
(in 2016)
70
(in 2015)
87
(in 2015)
69
(in 2015)
68
(in 2015)
74
(in 2014)
82
(in 2014)
78
(in 2014)
64
(in 2014)
93
(in 2013)
67
(in 2013)

We believe time and effort spent preparing in advance for an SFC inspection is well spent. Please contact us if you need our assistance.

Another free year of annual licensing fees!

The SFC has decided to waive annual licensing fees for another year from 1 April 2018 to 31 March 2019 for all licensed corporations, registered institutions and licensed individuals. The waiver only applies to annual licensing fees but not to fees for licence applications or transfers of accreditation. Details are available here.

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