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Singapore MAS Risk management Framework (RMF), Compliance Policy and AML / CFT

We are a leading regulatory compliance consultant firm in Singapore that can help you in preparing your RMF, Compliance Policies and AML / KYC Policies.

Singapore MAS Compliance Policy, Risk management Framework- RMF


If you have a Company in Singapore and if it operates in the financial Sector, then there is a higher chance that you may need a license to be obtained from the Monetary Authority of Singapore. During the process of applying for the license you would have heard about these three documents, namely:

  • Risk Management Framework – (RMF) / Metrics
  • Compliance Policy &
  • AML / CFT policy

So in this article get a brief idea of what these documents are.

What is a Risk Management Framework (RMF)

Risk management framework is the one that covers and documents all the risks that an enterprise faces. Normally every business (non-finance one also) is always exposed to the risks. For example, a retail shop has a risk that it may sell some expired food product which may create problem for the consumer. However in these non-finance companies, there is no practice of creating a Risk Management documents as such.

However when it comes to the business of fund management – These companies are essentially dealing with large amounts of money belonging to third party(Frequently in excess of 100 Million $). So the Monetary Authority of Singapore has put in requirement to have a documented risk management Framework for certain classes of licenses and have it addresses through your compliance policies.

What is a Risk management Metrics

Once your risk assessment is carried out, and you have finalised your Risk management Framework, the next thing you will prepare is Risk Management Metrics (Indicators). This is usually a single page table indicating the severity of various risks that are applicable for your fund operations.

Once this is prepared it will give you idea of all risks your organisation is exposed to and the relative severaity of each of the risks.

What is the Compliance Policy

Once the above two documents are prepared, the next thing to prepare is the compliance policy. The compliance policy will need to be matching your Risk management Framework and also the identified risks. (Please note every license requires a compliance policy but RMF is not necessary in each case).

What are the Contents of Risk Management Framework and Compliance Policy

In a way both these documents are related to each other as the Compliance manual addresses the risks identified in RMF. Broadly the contents of these documents are as :

  • Role of Board
  • Risk Culture
  • Various types of Risks – Operational, Financial etc
  • Policy Controls like Segregation of Duties, AML policy, Employee hiring Policy, Employee background check policy, Leave policy, Business Decision Approval policies
  • Remediation – Audit, Reviews, Conflict of interest, PII (insurance)

What is an AML / CFT (Or KYC) Policy

I think this point does not need much explanation. Everybody in the finance industry knows this. If you are onboarding a new customer you need to carry out proper background checks for the same. In case of the fund the background of the beneficial owners of the fund money needs to be checked. Since the amount of money involved is usually large, the checks needs to be carried out should be through, proper and in sufficient details.

Summary : We can help you on RMF and Policies

If you need help in the preparation of your RMF, Compliance Policies, and AML policies, you can engage our services. Our Team is well experienced in these matters. You can also avail any of the additional Services.

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