Implementation Guidance Ep 200 Ig 2 - Anti-Money Laundering And Countering The Financing Of Terrorism - Institute Of Singapore Chartered Accountants Page 42
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47EP 200 IG 2
ANNEX 2
EXAMPLES OF FACTORS TO CONSIDER IN AML/CFT RISK ASSESSMENT
Are the client’s company accounts updated?
Yes
No
Does the client’s shareholders and/or directors frequently change, and the
Yes
No
changes are unaccounted for?
SECTION C: COUNTRY / TERRORITY RISK FACTORS
Question
Response
Yes
No
Is the client, beneficial owner of the client or person acting on behalf of the
client from or based in a country or jurisdiction in relation to which the FATF
20
has called for countermeasures
?
The following would be applicable: nationality, country of incorporation /
registration, residential address, registered address, address of principal
place of business.
Is the client, beneficial owner of the client or person acting on behalf of the
Yes
No
client from or based in a country or jurisdiction known to have inadequate
21
AML/CFT measures
?
The following would be applicable: nationality, country of incorporation /
registration, residential address, registered address, address of principal
place of business.
Does the client, beneficial owner or person acting on behalf of the client have
Yes
No
22
dealings in high risk jurisdictions
?
SECTION D: SERVICES / TRANSACTIONS RISK FACTORS
Response
Question
Is the business relationship with the client established through online, postal
Yes
No
or telephone, where non face-to-face approach is used?
Has the client given any instruction to perform a transaction (which may
Yes
No
include cash) anonymously?
20
Refer to the FATF website for list of jurisdictions which the FATF has called for countermeasures.
21
This can be determined by the professional firm, those notified and required of the firm by relevant authorities, or those id entified
by the FATF.
22
Refer to the FATF list of high-risk and non-cooperative jurisdictions to determine which countries are high-risk jurisdictions:
42
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