Feedback paper on consultation paper no. 9 2023

Summary

This is a JFSC feedback paper summarising industry responses to Consultation Paper No. 9 2023, which proposed expanding the annual AML/CFT/CPF and other supervisory risk data collection (SRDC) exercise. It sets out the JFSC's final decisions on which proposed additional questions will proceed, be delayed, or be dropped, and confirms the timing for launching the 2023 data collection exercises.

• Excluded: 10 additional proposed questions will not be included (e.g. overall ML/TF/PF risk appetite question FC1, screening tool last-updated question SM2, sanctions hit potential-proliferation-financing question SM10, non-material/non-regulatory breach question CR1).
• Delayed: 34 additional questions are postponed from the 2023 exercise, including wire transfer purpose/rationale questions (WT2, WT4), the Table 2 Sound Business Practice customer count (FC6, to be requested for 2024 data in the 2025 collection), and complaint categorisation (CR16).
• Retained: 29 additional questions will be included in the 2023 AML/CFT/CPF and other Supervisory Risk Data Collection exercise (e.g. FC2 to FC5, WT1, WT3, most sanctions monitoring questions SM1, SM3 to SM9).
• LPA data collection: The JFSC will proceed with issuing the separate legal persons and legal arrangements (LPA) data collection for the 2023 reporting year.
• Launch and submission window: Both the SRDC and LPA data collections are aimed to launch on 1 February 2024, with an extended submission period running to 31 May 2024.

The paper is informational feedback rather than a standalone binding instrument, but it confirms the scope and timing of data that supervised/registered persons will be required to submit as part of the 2023 collection cycle.

Key obligations

• Supervised/registered persons must complete and submit the 2023 AML/CFT/CPF and other Supervisory Risk Data Collection (SRDC), including the 29 retained additional questions, once the exercise launches.
• Supervised/registered persons must complete and submit the separate 2023 legal persons and legal arrangements (LPA) data collection.
• Firms should submit the required data within the extended submission window from 1 February 2024 to 31 May 2024.

Applies to

banking businesses, trust company businesses, fund services businesses, investment businesses, general insurance mediation businesses and/or insurance businesses, designated non-financial businesses and professions (DNFBPs), non-profit organisations (NPOs), registered persons under the Regulatory Laws (AIF Regulations, BB(J)L, CIF(J)L, FS(J)L, IB(J)L)

Deadlines

• 1 February 2024: Planned launch date for both the 2023 AML/CFT/CPF and other supervisory risk data collection (with the 29 retained new questions) and the LPA data collection.
• 1 February 2024 to 31 May 2024: Extended submission period for supervised/registered persons to provide the additional supervisory risk data.