Section 74

take appropriate steps to identify, assess and understand the money laundering and terrorism financing risks in relation to —

its pawners;

the countries or jurisdictions that its pawners are from or in;

the countries or jurisdictions in which it has operations; and

its products, services, transactions and delivery channels;

for the purpose of paragraph (a) —

document its risk assessments;

consider all relevant risk factors before determining the overall level of risk and the appropriate type and extent of mitigation to be applied;

keep its risk assessments up to date; and

have appropriate mechanisms to provide its risk assessments to the Registrar;

develop and implement internal policies, procedures and controls, which must be approved by its senior management, to manage and effectively mitigate the money laundering and terrorism financing risks identified by it or notified to it by the Registrar, including —

making appropriate compliance management arrangements, including the appointment of a compliance officer at the management level; and

applying adequate screening procedures when hiring employees;

have an ongoing programme to train employees on the internal policies, procedures and controls in paragraph (c);

have an independent audit function to test the internal policies, procedures and controls in paragraph (c); and

monitor the implementation of the internal policies, procedures and controls in paragraph (c), and enhance them if necessary.

must be applicable to the pawnbroker’s branches and subsidiaries, whether in Singapore or elsewhere;

must include the measures specified under subsection (2);

must be appropriate to the business of the pawnbroker’s branches and subsidiaries;

must be implemented effectively at the level of the pawnbroker’s branches and subsidiaries;

must include policies and procedures for providing and sharing information required for the purposes of customer due diligence measures under Part 2 of the Third Schedule and generally for the management of risks relating to money laundering and terrorism financing; and

must include adequate safeguards on the confidentiality and use of information exchanged between the pawnbroker and its branches and subsidiaries.

the pawnbroker must require the management of that branch or subsidiary to apply the more stringent set of laws, to the extent that the law of the host country or territory permits; and

where that branch or subsidiary is unable to fully apply the more stringent set of laws, the pawnbroker must report this to the Registrar and must, in lieu of paragraph (a), comply with any directions that may be given by the Registrar.