The Monetary Authority of Singapore (MAS) has revoked the Capital Markets Services (CMS) license of Apical Asset Management Pte. Ltd. (AAMPL) for violating MAS’ AML/CFT regulations. AAMPL’s operations were deficient in many fundamental AML/CFT measures during 2013-18.
For example, some of AAMPL’s clients used complex, multi-layered ownership structures. Moreover, the company failed to conduct any enterprise-wide ML/TF risk assessment (EWRA) or a similar assessment on its customers. It should be noted that MAS requires financial institutions to conduct an EWRA at least once every two years, or sooner under specific circumstances. Without an EWRA, entities cannot identify their risks and vulnerabilities and be prepared for them. AAMPL also did not undergo independent audits for an assessment of the efficacy of its AML/CFT measures.
Given its many violations and deficiencies, AAMPL was at a high risk of money-laundering. Indeed, AAMPL’s deficiencies led to its failure to conduct timely enhanced monitoring of an account linked to a politically exposed person. For failing to ensure compliance with the regulations, MAS has also reprimanded AAMPL’s CEO and Board in addition to the withdrawal of the company’s CMS license.