Singapore: How may a reporting entity demonstrate that it has undertaken reasonable efforts to obtain the necessary consent of its customer or counterparty?

A reporting entity should establish written policy and procedures as well as internal  controls to seek the requisite consent from its customer or counterparty. Such policy and  procedures should provide guidance on when or how often to request or to repeat  requests for consent, e.g. upon changes in law, or when the customer or counterparty  requests to enter into new trades, or on a certain time frequency.  

The policy and procedures should also provide guidance on the actions that a reporting  entity should take towards a customer or counterparty who has yet to provide the  requisite consent or refuses to provide consent, e.g. to suspend trading relationships until  consent is obtained.  

References:  

• Regulations 11 and 11C of the SF(RDC)R