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Dubai Regulator Fines Singapore Private Bank Bank of Singapore $1.12 Million for Insufficient Anti-Money Laundering Control, Involved in Insurance Advisory Process without Required License
17th November 2022 | Hong Kong
Dubai Financial Services Authority (DFSA, Regulator) has fined OCBC independent private bank Bank of Singapore $1.12 million for insufficient Anti-Money Laundering (AML) control, and being involved in insurance advisory process with clients without required license (Introducing agent to 3rd-party insurance broker). DFSA: “The Dubai Financial Services Authority has imposed a fine of USD 1,120,000 on the DIFC branch of Bank of Singapore for a number of contraventions of DFSA legislation, including for having inadequate systems and controls including those relating to anti-money laundering (AML) … …. The DFSA also found that the Bank had acted outside the scope of its DFSA Licence by Arranging Deals in Investments in relation to rights under Long-Term Insurance contracts, when not authorised to do so. The Bank has since applied to the DFSA for permission to do so.” Ian Johnston, DFSA Chief Executive: “The DFSA has a high degree of concern over any AML related contraventions and will take appropriate action to make sure that the systems and controls implemented by Authorised Firms operating in the DIFC are robust.” The amount of fined was reduced from $2 million to $1.12 million, with Bank of Singapore agreed to DFSA an Enforceable Undertaking (EU) to remediate the failings. View: Dubai Decision Notice on Bank of Singapore
“ Dubai Regulator Fines Singapore Private Bank Bank of Singapore $1.12 Million for Insufficient Anti-Money Laundering Control, Involved in Insurance Advisory Process without Required License “
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Dubai Financial Services Authority Announcement on Bank of Singapore Fined $1.12 Million

10/11/22 – The Dubai Financial Services Authority (DFSA) has imposed a fine of USD 1,120,000 (AED 4,113,200) on the DIFC branch of Bank of Singapore Limited (the Bank) for a number of contraventions of DFSA legislation, including for having inadequate systems and controls including those relating to anti-money laundering (AML).
The amount of the fine was reduced because the Bank offered the DFSA an Enforceable Undertaking (EU) to remediate the failings and agreed to settle the matter, reducing the fine amount from USD 2,000,000 (AED 7,345,000).
The DFSA found deficiencies in the Bank’s:
- AML business risk assessments;
- assessment of the risks posed by its Clients;
- Customer Due Diligence (CDD) and Enhanced CDD practices;
- identification of its Clients’ sources of wealth and sources of funds; and suspicious activity reporting.
The DFSA also found that the Bank had acted outside the scope of its DFSA Licence by Arranging Deals in Investments in relation to rights under Long-Term Insurance contracts, when not authorised to do so. The Bank has since applied to the DFSA for permission to do so.
The DFSA acknowledges that the Bank has also provided the DFSA with an EU in which the Bank agrees to:
- remedy the deficiencies in its systems and controls; and
- engage an external compliance expert to assist the Bank in complying with its obligations and to verify that the remediation has been completed.
Ian Johnston, Chief Executive of the DFSA, said: “The DFSA has a high degree of concern over any AML related contraventions and will take appropriate action to make sure that the systems and controls implemented by Authorised Firms operating in the DIFC are robust.”
Copies of the Decision Notices and Enforceable Undertaking setting out full details of this matter can be found in the Decision Notices section of the DFSA website.
The Dubai Financial Services Authority (DFSA) is the independent regulator of financial services conducted in and from the Dubai International Financial Centre (DIFC), a purpose built financial free zone in Dubai. The DFSA’s regulatory mandate covers asset management, banking and credit services, securities, collective investment funds, custody and trust services, commodities futures trading, Islamic finance, insurance, crowdfunding platforms, money services, an international equities exchange and an international commodities derivatives exchange. In addition to regulating financial and ancillary services, the DFSA is responsible for administering Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) legislation that applies to regulated firms and Designated Non-Financial Businesses and Professions in the DIFC. Please refer to the DFSA’s website for more information.
Ian Johnston was appointed Chief Executive of the DFSA in September 2022. He previously served as the DFSA’s Chief Executive from 2012-2018. A lawyer by background, Ian had several senior executive roles in the private sector, including as CEO of one of Australia’s major trustee companies. The second half of his career being in regulation, Ian was an Executive Director at the Australian Securities and Investments Commission; Special Advisor at the Hong Kong Securities and Futures Commission; and since 2019, consulting to and advising a number of financial regulators in Europe, Asia and the Middle East.
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