Internal Audit
For LFMCs or RFMCs with less than 5 people, is an internal audit still required?
Yes, LFMC or RFMC are categorized as FMCs under SFA 04-G05 - according to section 3.17 of the SFA 04-G05, “MAS expects the business activities of an FMC to be subject to adequate internal audit. The internal audit arrangements should be commensurate with the scale, nature, and complexity of its operations.”
In addition, as stated in section 13(b)(iv) of the Securities and Futures (Licensing and Conduct of Business) Regulations, the “holder of a capital markets services licence shall ensure that the business activities of the holder are subject to adequate internal audit.”