FREQUENTLY ASKED QUESTIONS (FAQs) ON ANTI-MONEY LAUNDERING & COUNTERING THE FINANCING OF TERRORISM (AML/CFT)

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1 FREQUENTLY ASKED QUESTIONS (FAQs) ON ANTI-MONEY LAUNDERING & COUNTERING THE FINANCING OF TERRORISM (AML/CFT) A) FAQs relating to Customer Due Diligence Q1 What steps should a salesperson take to verify a client s identity? A1 The salesperson should record the full name and particulars of the client if the client is an individual. He should verify the name and particulars of the client by requesting for the NRIC or passport. If the salesperson is dealing with an individual who represents a company, he should ask for proof that the individual is authorised to represent the company. Once this has been established, he should record the full name and particulars of the individual and verify his identity accordingly. The salesperson should also record the full name and particulars of the company. Q2 What is a Beneficial Owner? A2 A beneficial owner is the person who has ultimate interest in the transaction and who has ultimate control over the client. He is the person on whose behalf a transaction is being conducted. Q3 In the process of screening clients against the UN sanction lists, an estate agent (EA)/salesperson comes across a partial name match. What is the EA/salesperson supposed to do? In the process of screening, an EA/salesperson comes across a full name match (or true match). What is the EA/salesperson supposed to do? A3 If there is a partial name match, the EA/salesperson should conduct customer due diligence to find out whether the nationality and age range of the client matches the information provided in the UN Sanction list. If there is a nationality and age range match, the EA/salesperson should lodge a Suspicious Transaction Report (STR) as soon as is reasonably practicable. 1

2 If a true match is confirmed (i.e. full name, nationality and age range match), the EA/salesperson should refrain from further dealing with the person and should not proceed with the transaction. A STR should be lodged as soon as is reasonably practicable. Where the EA/salesperson is certain that the name match is a false hit (e.g. different nationality and age range from the information provided in the UN Sanction list), a STR need not be lodged. Q4 Please provide more examples of prominent public functions for Politically Exposed Persons (PEP). How does an EA/salesperson determine if a client or beneficial owner is a PEP? A4 Prominent public function includes the roles held by a Head of State or government, government ministers, senior civil or public servants, senior judicial or military officials, senior executives of state owned corporations or senior officials of political parties, members of the legislature and senior management of international organisations. To determine whether a client or beneficial owner is a PEP, an EA/salesperson can use an Internet based search engine to obtain news or information on the person. Alternatively, EAs/salespersons could consider conducting a search through a commercial database provider. Q5 When do EAs/salespersons file a STR on a PEP? A5 If a person is a PEP, EAs/salespersons should undertake enhanced customer due diligence on the business relationship. However, it is useful to note that a STR should not be filed solely on the basis that the person is a PEP or that a PEP has made a transaction. A PEP is after all an individual who, like a non-pep, needs to make use of financial services and purchase goods and services for their personal affairs or those of their dependents. A STR on a PEP should be lodged when the PEP s transactions are suspected of being connected with money laundering or terrorism financing (e.g. adverse news, circumstances surrounding the transaction are suspicious). The reasons for filing a STR related to non-peps and PEPs are similar. 2

3 Q6 Besides the MAS webpage on targeted financial sanctions, are there any other websites which EAs and salespersons need to take note of in doing CDD checks? A6 As part of CDD, EAs and salespersons are required to screen their clients against MAS targeted financial sanctions webpage, which has a list of UN sanctioned entities and individuals from a number of countries. EAs and salespersons are also required to check against the FATF public list of high-risk and non-cooperative jurisdictions. The links to both webpages are provided in the Circulars that CEA has issued. Q7 What if an EA/salesperson unwittingly assisted in a sale/ purchase of a property for an individual on the UN sanction list or a criminal? A7 When there is suspicion that property could be linked to crime, the best course of action is to lodge a STR and alert the authorities. EAs and salespersons should not be overly concerned as long as they have conducted the necessary due diligence and undertaken the necessary follow-up measures as required in the Practice Circular. Q8 CEA s Practice Circular mentioned that EAs and salespersons have to pay attention to business relations and transactions with individuals from higher risk countries. What countries are CEA referring to? A8 Paragraph 29 of CEA s Practice Circular provides a link to the FATF public list of high-risk and non-cooperative countries in the area of AML/CFT. Examples of such countries are Iran and North Korea. B) FAQs relating to STR Reporting Q9 When should an EA/salesperson lodge a STR? Should the EA/salesperson report the transaction to STRO first or close the deal first? A9 EAs and salespersons have to make an assessment on the level of suspicion based on the knowledge obtained about the client and the property they are dealing with. Under Section 39 of the CDSA, when a person has reason to suspect that a property or transaction is linked to 3

4 criminal conduct, he should lodge a STR as soon as is reasonably practicable. If the EA/salesperson assesses the business transaction to be of very high risk (e.g. the person has a full name match with a known terrorist or drug trafficker), the EA/salesperson should not close the deal and should file the STR as soon as is reasonably practicable. EAs/salespersons should note that there are costs of non-compliance (e.g. reputational risk should it be reported that the EA or its salespersons were complicit in money laundering, terrorism financing or had sanctioned evasion of criminals). After a STR is lodged with STRO, EAs/salespersons can contact the STRO hotline at to notify STRO of an urgent STR. If the matter is assessed by STRO to be indeed urgent, STRO will accord priority to the matter. Q10 Does Singapore have a similar regime as the United Kingdom where the STR filer (who has lodged a STR) can proceed with the transaction, if the financial intelligence unit or the authorities do not contact the STR filer after a stipulated time period? A10 In Singapore, we do not impose a stipulated time period for the STR filer to withhold the transaction. After a STR is lodged with STRO, EAs/salespersons can contact the STRO hotline at to notify STRO that they require advice on whether to proceed with the transaction. Q11 Is there anything an EA/salesperson has to do after lodging the STR? A11 After a STR is lodged with STRO, no further action is required unless otherwise instructed by STRO or the authorities. Q12 For cases under investigation or which have been subject of STRs, how long must the EA/salesperson retain such records? A12 Under Section 36 of the CDSA, all financial transaction documents should be retained for a minimum period of 5 years. These documents 4

5 would include originals or copies of documents relating to property transactions. EA/salesperson shall also retain records pertaining to cases under investigation or which have been the subject of a STR for a longer period in accordance with any order from STRO or other relevant competent authorities. Q13 When an EA/salesperson lodges a STR and after investigation, it was found that the purchaser is involved in money laundering activities, what will happen to the property that is sold? A13 In the event that the property is found to be linked to criminal proceeds, the authorities may take the necessary action to prohibit the disposal of or dealing with, the property. Q14 Will the identity of the STR filer remain confidential? How is the filer s identity protected? A14 Under Section 56 of the CDSA, STRO is required to preserve the secrecy of the information obtained under the CDSA, including STR information. Under Section 40A of the CDSA, no STR information shall be admitted in evidence in any civil or criminal proceedings. Moreover, no witness in such proceedings shall be obliged to disclose the identity of the STR filer. If a document which is used as evidence in court proceedings were to contain any entry that could lead to the discovery of the identity of the STR filer, the court shall cause the entry to be obliterated to protect the identity of the STR filer. Accordingly, STRO has strict safeguards and measures in place to protect the identity of the STR filer. Q15 Will a client named in the STR be in any trouble with the authorities? Will he be arrested? A15 A STR is not an allegation of crime, nor is it an accusation that a person has committed a crime. It is essentially a suspicion that some property could be linked to criminal conduct. In many cases, there might well be no evidence of any criminal conduct. 5

6 STRO treats each STR as a piece of important information that could potentially lead to the detection of criminal conduct. A client named in a STR will not be deemed to have committed a crime. The information contained in a STR will have to be verified. An investigation will be launched if necessary. The decision to arrest anyone in regard to a criminal investigation will depend on the circumstances of the case and not entirely on the basis of the STR. C) Others Q16 Are there any differences in meeting the AML/CFT requirements between large EAs and small EAs? A16 The application of AML/CFT procedures is on property transactions and are applicable to all EAs, whether large or small. However, EAs may differ in the way they comply with the requirements. CEA expects that there would be differences between how a large and small EA meet the requirements. For example, the procedures and the monitoring needed in a small EA of a few salespersons are unlikely to be as elaborate as that for a large EA with more than a thousand salespersons. A large EA may have an IT system to trigger higher-risk transactions for the attention of the Management. A small EA could trigger higher-risk transactions through the use of internet based searches. If the EA is a sole-proprietorship, it might not make sense for the Key Executive Officer to audit himself. However, procedures on AML/CFT should be properly documented and documentation on compliance with the procedures when carrying out property transactions should be kept and made available for inspection. *************** 6

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