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The Registry for Trust and Company Service Providers flagged two amendments gazetted on 6 November. Legal Notices 145 and 146 concern the Democratic Republic of the Congo and Libya respectively.
Where a client, beneficial owner or transaction has a relevant connection, check the two notices and record the implications for your screening process.
Electronic filing opened on 5 November. The statutory deadline remains six months after the financial year end. The IA will accept paper submissions during the transition through 31 October 2027.
Test account permissions before the deadline. Arrange for the responsible officer to reconcile the online fields with the audited accounts and auditors’ reports, and retain the filing record.
The TCSP Registry drew attention to two FATF statements issued on 30 October. One identifies high-risk jurisdictions subject to a call for action. The other covers jurisdictions under increased monitoring.
Check the version and review date of country risk ratings. Record how each statement and the client’s circumstances inform the action taken.
The IA explains how the appointing firm’s business model, conduct risks and authority delegated to the candidate inform its fit-and-proper assessment. It may invite the candidate to an interview depending on the case.
Have the candidate work through a real example from the prospective firm, from identifying a risk and directing a remedy to reporting the outcome to the board.
The MPFA announced that eMPF may require claimants to produce original supporting documents. Medical certificates for claims on grounds of total incapacity or terminal illness have also been revised.
Update form links used by frontline staff and use a training case to practise explaining an original-document request and the revised medical certificate.
On 21 September the Registrar of Money Lenders issued revised wording for the risk warning under licensing condition 9(b), for use from 1 January 2027.
Identify advertisements that will still be displayed in January, prepare replacement artwork using the official wording and schedule the changeover.
An intermediary reused a member’s personal information from an earlier transaction to transfer MPF benefits without the member’s knowledge or authority. The MPFA suspended the intermediary’s registration for 28 months.
Sample recent transfers and check that each file identifies the member’s instruction for that specific transaction and who verified it.
The revised guidelines took effect on 1 August. They cover the prohibition on asking borrowers for loan referees, tighter advertising controls and a debt servicing ratio cap for unsecured personal loans to low-income earners.
Check application forms and advertisements against the conditions on the licence. Review the income evidence and debt servicing calculations for loans within scope.
Disciplinary cases involving long term insurance illustrated gaps in customer due diligence. These included misidentifying the policyholder, failing to verify a representative’s authority and omitting politically exposed person checks.
Use a corporate file to trace the evidence from customer identification and signing authority through to screening results in an internal review or training exercise.
