Anti-Money Laundering & Counter-Terrorism Financing

Some non-exhaustive examples of such indicators that could be considered include:

a) Adverse information e.g. whether there is adverse news on the customer and its beneficial owner; whether the customer or beneficial owner is a sanctioned person;
b) Business operations/dealings e.g. whether the customer has operations in or dealings with high-risk jurisdictions, or is in a high-risk sector/industry;
c) Country of incorporation/country of registration (for a legal person) e.g. whether the customer or any beneficial owner of the customer is in or from a high-risk jurisdiction;
d) Customer behaviour e.g. whether the customer is reluctant or refuses to provide information/documents upon request ;
e) Nationality/country of residence (for a natural person) e.g. whether the customer is in or from a high-risk jurisdiction;
f) Ownership and control structure e.g. whether the structure appears unusual or excessively complex, with no legitimate reasons for the unusualness/complexity; whether there are nominee directors and shareholders;
g) Participation in tax amnesty programme i.e. whether the customer or any beneficial owner of the customer had participated in such a programme;
h) Politically exposed person (“PEP”) status i.e. whether the customer or any beneficial owner of the customer is a PEP or family member or close associate of a PEP;
i) Tax residency e.g. whether the customer changes his tax residency to a jurisdiction that has no exchange of tax information arrangement with Singapore and there are no legitimate reasons for doing so.