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Licensed and exempt entities in Singapore that have cross-border arrangements with their foreign related corporations are required to notify the MAS. They also must conduct an independent audit of these arrangements, meaning that it’s crucial to start planning the process and reviewing your existing arrangements in good time.
What is required by the MAS if I’m a licensed or exempt firm?
The independent audit applies to cross-border arrangements (CBA) with foreign related corporations under the exemption for CBA framework, or exemption framework. In addition to the independent audit, licensed and exempt entities also need to submit an annual declaration to the MAS under Form FR declaring that they have satisfied all relevant regulations. As part of this annual declaration, firms need to be audited and certified by an independent assurance function (or service provider).
The exemption framework has been ‘live’ since October 2021. Firms in scope first had to submit annual declarations to the MAS in 2023 (for their CBAs in 2021 / 2022). For example, if your firm’s financial year end is December 2024, you are required to submit a declaration to the MAS by May 2025.
What can I improve in my documentation to remain complaint?
Our Singapore team continues to support several firms with their CBA audits and certifications, so we’re well-versed with what needs to happen at each stage of the process.
We generally recommend that firms have comprehensive policies and procedures for their CBAs. Based on our past audits we noted weaknesses in descriptions of the activities performed by foreign representatives of fund managers, and in the foreign representative register. For brokers, we observed that certain outsourcing arrangements were incorrectly deemed as CBAs.
How can Bovill Newgate help audit and certify my cross-border arrangements?
Our specialist team can provide you with the independent CBA audit required and the certification that the MAS requires. As part of the audit, we will review your policies, procedures and controls, including controls related to record keeping, anti-money laundering, and countering the financing of terrorism. At the end of the audit, you will receive a written report detailing the gaps we have found and our recommended remedial action, so that you know what to prioritise. Our team will also issue the certification to the relevant MAS officer-in-charge.
Get in touch if you need assistance on getting audited and certified, or if you have any questions around managing cross-border arrangements.
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