Implementation Guidance Ep 200 Ig 2 - Anti-Money Laundering And Countering The Financing Of Terrorism - Institute Of Singapore Chartered Accountants Page 41
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47EP 200 IG 2
ANNEX 2
EXAMPLES OF FACTORS TO CONSIDER IN AML/CFT RISK ASSESSMENT
“Yes” to any of the questions in Sections B, C and D serves as indicators of higher risk factors.
Where there is one or more “yes” responses, professional judgement must be exercised, with
reference to the policies and procedures of the professional firm, as to the nature and extent of
customer due diligence to be carried out. Risk factors should be discussed with the designated
personnel as per the policies and procedures of the professional firm, such as the Money
Laundering Reporting Officer (MLRO).
SECTION B: CLIENT’S RISK FACTORS
Question
Response
Yes
No
Is the client, any of the beneficial owner of the client or person acting on
behalf of the client a Politically Exposed Person (PEP), family member of a
PEP or close associate of a PEP?
The professional firm has performed further screening of details of client,
Yes
No
beneficial owner of the client, person acting on behalf of the client, or
connected party of the client against other information sources, for example,
Google, the sanctions lists published by the Office of Foreign Assets Control
of the US Department of the Treasury, and/or other third party screening
database.
Are there adverse news or information arising?
19
Is the client in a high-risk industry
?
Yes
No
Does the client have nominee shareholder(s) in the ownership chain where
Yes
No
there is no legitimate rationale?
Where applicable, do the nominee shareholders represent majority
Yes
No
ownership?
Is the client a shell company?
Yes
No
Yes
No
Does the client have unusual or complex shareholding structure (e.g.
involving 3 layers or more of ownership structure, different jurisdictions,
trusts), given the nature of its business?
Is the client a charitable or non-profit organisation that is NOT registered in
Yes
No
Singapore (charities.gov.sg/charity/index.do)?
Is the client’s business cash-intensive?
Yes
No
Does the client frequently make unaccounted cash transactions to similar
Yes
No
recipients?
19
As determined by the firm, such as with reference to publications and guidance issued from time to time by the FATF.
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