Institutions deemed as having higher risk are subject to more frequent onsite inspections. Let me cite some outcomes from our inspections. Institutions that have failed to meet our requirements have been warned or reprimanded in writing. A few have been required to appoint external consultants to conduct a thorough review of their AML/CFT frameworks; others have been asked to increase the resources devoted to this function. In a couple of cases, where the frameworks and procedures were adequate but ineffective management oversight resulted in inadequate implementation, we have asked the senior management to be replaced. In all cases, MAS informs the institution’s parent supervisor of our findings and concerns. Our supervisory approach aims to be preventive in nature. This means that sanctions can be taken against financial institutions for weak AML/CFT controls, even if no predicate offence has occurred. Having reviewed our regulations and our supervisory and enforcement actions, the FATF assessors concluded, “Singapore’s AML/CFT sanctions regime is effective, proportionate, and dissuasive”. In a nutshell, while a lot has been done, our institutions can always do better. MAS is reviewing whether we need to increase our supervisory intensity and is considering if we should make public, sanctions against persistently or egregiously errant institutions. Strengthened cross-border co-operation The third prong of our efforts is international co-operation.
Given the cross-border nature of illicit financial activities, it is not enough that we have strong regulation and supervision in  BIS central bankers’ speeches  5  Singapore; we must be able to co-operate effectively with supervisory authorities and enforcement agencies abroad. Singapore contributes actively to the work of the FATF, the Global Forum on Transparency and Exchange of Information for Tax Purposes, and the AML/CFT Expert Group under the Basel Committee, to shape well-balanced international standards that are effective and proportionate. MAS co-operates with our international counterparts, through sharing inspection reports, participating in supervisory colleges, and facilitating home regulator visits. We also co-operate with home supervisors to enhance AML/CFT controls and standards not only at the branch but at the group level for financial institutions operating across borders. Internationally, the new emphasis is on co-operation in pursuing cross-border tax offences. Singapore has endorsed the internationally-agreed standard, known as Article 26 of the OECD Model Tax Convention on Income and Capital, for the exchange of information upon request, and is committed to supporting the effective implementation of this global standard. Singapore amended legislation in 2009 to lend effect to its obligations and has since signed 30 Avoidance of Double Taxation Agreements incorporating the new standard. This ensures that we are able to assist in foreign requests for information on a person’s tax position, so long as the request is clear, specific, relevant and backed with good reason. Some people think that Singapore’s banking confidentiality regime fetters such international cooperation.