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On 8 February 2022, the Monetary Authority of Singapore released a new circular for Financial Institutions (FIs), providing detailed guidelines on the increasing usage of Non-face-to-face (NFTF) measures and technologies for customer due diligence (CDD). 

In the report, the regulator openly encourages the responsible adoption of new technologies to mitigate money laundering, terrorism financing and proliferation financing (ML/TF/PF) risks. To better support FI’s understanding and assessment of available technology solutions, the Circular sets out very specific industry good practices on how to approach the procurement, implementation and on-going review of third-party technologies. 

Within the document, the majority of the attention is dedicated to remote onboarding procedures for retail or individual customers, referred to as Natural Persons.  

However, there are also a few important elements that are relevant to the area of corporate customer onboarding in the sections dedicated to Legal Persons and Legal Arrangements. 

Click here to view and download a copy of the Circular. 

We have identified four key points relevant to corporate onboarding in the MAS Circular:
1

Limited reliability of video-conferencing

CDD documents that lack the requisite authenticity markers (such as a foreign certificate of incorporation) should not be verified via video-conferencing alone.
2

Acceptance criteria for scanned copies of CTC documents

Scanned copies of CTC documents may be accepted, provided the FI puts in place measures to detect possible fraudulent or tampered documents.
3

Encouragement for new technology adoption

FIs are encouraged to adopt new technology solutions and digital signatures or watermarks to verify the authenticity of soft copy documents.
4

Internal technology assessment guidelines

FI should conduct an internal assessment of the effectiveness of the technology solution in mitigating impersonation and fraud risks, prior to implementing the technology solution and continuous monitoring afterward.

1. Limited reliability of video-conferencing

Verifying the corporate structure of a company registered in Singapore and fully owned by Singapore residents is something that local financial institutions can do fairly easily.

However, that is not the case for foreign companies or companies registered in Singapore but owned by foreign stakeholders. In these instances, MAS makes it clear that relying on video-conferencing alone is not a viable option and that compliance teams should conduct additional checks to verify that soft copies of incorporation documents are genuine. 

By partnering with a trustworthy RegTech provider, FIs can remove the need for certified copies of incorporation documents also when dealing with international companies or local companies with intricate corporate structures.  

At Know Your Customer, we offer a one-stop solution that provides direct connections to global company registries in real-time. Through one easy-to-use interface, compliance officers can instantly download official soft copies of required company documents directly from their primary source. This approach provides the highest level of security and timeliness.

When FIs have official documents accessible conveniently at their fingertips, there is no need to spend a lot of time, capital and human resources requesting soft copies from the customers or developing know-how and expertise internally to verify them. 

2. Acceptance criteria for scanned copies of CTC documents

While carrying out compliance procedures and measures to detect possible fraudulent and tampered documents on a one-on-one basis may be a solution for the short term, this only works for financial institutions with experienced compliance talents in-house and a limited volume of documents to verify.

However, pushed by the rise of virtual banks, digital onboarding is increasingly becoming a key expectation for both retail and corporate clients in Singapore. In this context, the processing speed of customers’ applications will be seen as a key differentiator for FIs. 

At scale, it is simply not possible to verify massive quantities of scanned documents relying solely on manual checks or visual comparisons due to the strain on human resources and the delays that this approach will inevitably determine. 

Once again, Know Your Customer can help. Our solutions enable compliance teams to source incorporation documents directly from their official source, completely removing the need for scanned copies that require verification. This approach, especially when fully integrated with front-end application forms on FIs’ websites, has the power to sensibly accelerate the onboarding process for corporate clients, while delivering a much-improved customer experience. 

3. Encouragement for new technology adoption

The Circular is quite clear in its recommendation to embrace authenticating technologies, stating that “in the longer term, FIs are encouraged to adopt new technology solutions and digital signatures or watermarks to verify the authenticity of soft copy documents”. 

But why delay such a decision to “the longer term”, when there are already extremely cost-effective and reliable solutions on the market?

In fact, the incidence of forgery, tampering and fraud in the world is on the rise, and fraudsters are becoming more ingenious by the day. 

We have already remarked how sourcing company documents at their original source is the best way for FIs to protect themselves against the risk of corporate impersonation. With Know Your Customer, compliance teams don’t have to worry about creating accounts and familiarising themselves with different registries from around the world but can access the most reliable data through an incredibly easy-to-use interface.

Additionally, to validate UBOs’ ID documents, Know Your Customer provides AI-based ID Verification, authenticating photos of passports, driving licenses and ID Cards from 180+ countries around the world. The system is able to detect even the smallest sign of tempering, achieving a level of precision that is simply not possible through traditional manual checks.

4. Internal technology assessment guidelines

It is essential for financial institutions to have a clear understanding of the capabilities of any solution they intend to use for NFTF onboarding. The Circular reminds compliance teams to also make sure that any implementation respects the MAS Technology Risk Management guidelines. 

Choosing a reliable partner that can provide the answers and assistance needed on this journey is of vital importance.  

Since 2015, Know Your Customer has been providing remote CDD solutions to financial institutions across 18 jurisdictions worldwide.

The proven success of our partnership formula is based on three factors: 

  • Deep understanding of local and international regulatory requirements for CDD and AML compliance 
  • On-going improvements and upgrades to ensure our clients have access to the most cutting-edge solutions
  • Transparent communications to fully understand customer needs and establish the best course of action in any situation 

You can discover more about the way we work and what we can achieve together by exploring our Case Studies.

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