This has resulted in the intensification of our supervision on areas or businesses that are more prone to ML/TF risks, or where controls have been found to be lacking from past inspections. 17. We have organised and will organise more industry engagements to share supervisory findings on common lapses and good practices at the end of each series of inspections. This is intended to help level up controls over time. 2/5  BIS central bankers' speeches  18. Our inspections go beyond rules-based compliance. We focus on whether financial institutions demonstrate a good understanding of risks, and a good risk culture within the organisations. We much prefer that FIs adopt a proactive approach in meeting their regulatory obligations than a passive rule-based attitude. Let me elaborate on this. 19. One area relates to governance. You are all familiar with the common thinking of having three lines of defence. Recently, there are suggestions to augment this with a “four lines of defence” model for better governance in financial institutions. The first line involves frontline and management controls within business units; then compliance and risk management functions as the second line; and the audit function as the third line. A newer fourth line involves interactions of the FI with its external auditors and regulators. An FI’s senior management and board should monitor and be satisfied that these lines are effective. Senior managers should never “look the other way” on suspicious transactions, even if they involve major clients who are significant revenue sources.

Should this happen, the MAS will take tough enforcement actions for breaches of our regulatory requirements. Where laws are broken, we will also not hesitate to refer these to the law enforcement agencies for investigation and prosecution. 23. Last year, we announced the centralization of our enforcement function into a single department. The team in our Enforcement Department will deepen our capabilities in investigative work that were previously undertaken by prudential supervisors. A centralised enforcement function in MAS will also allow us to take a holistic approach to “follow the funds” should these cut across different types of entities in our financial sector. 24. Let me now highlight the fourth key element of our AML/CFT framework: International Cooperation and Partnerships. 25. I have mentioned Singapore’s commitment to the international efforts to combat ML/TF risks. We fully support the important work of various international organisations including the FATF. In addition, it is important to have close supervisory co-operation between financial regulators and we hope to expand on our supervisory cooperation network. Another area which we will strengthen is our partnership with the financial industry. 26. While law enforcement and regulatory authorities have wide powers, the financial industry has an “on the ground” vantage point with front-line knowledge of business and clients. It is hence advantageous to adopt a collaborative “eco-system” approach to holistically deal with 3/5  BIS central bankers' speeches  ML/TF risks. Such a partnership should be as inclusive as practicable – involving law enforcement agencies, regulator and the industry.