Implementation Guidance Ep 200 Ig 2 - Anti-Money Laundering And Countering The Financing Of Terrorism - Institute Of Singapore Chartered Accountants Page 43
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47EP 200 IG 2
ANNEX 2
EXAMPLES OF FACTORS TO CONSIDER IN AML/CFT RISK ASSESSMENT
Has the client transferred any funds without the provision of underlying
Yes
No
services or transactions?
Are there unusual patterns of transactions that have no apparent economic
Yes
No
purpose or cash payments that are large in amount, in which disbursement
would have been normally made by other modes of payment (such as
cheque, bank drafts etc.)?
Yes
No
Are there unaccounted payments received from unknown or un-associated
third parties for services and/or transactions provided by the client?
Is there instruction from the client to incorporate shell companies with
Yes
No
nominee shareholder(s) and/or director(s)?
Does the client set-up or purchase companies or business entities that have
Yes
No
no obvious commercial purpose?
This would include:
Multi-layer, multi-country and complex group structures.
Setting up entities in Singapore where there is no obvious commercial
purpose, or any other personal or economic connection to the client.
Yes
No
Is there any divergence in the type, volume or frequency of services and/or
transactions expected in the course of the business relationship with the
client?
SECTION E: CLIENT RISK RATING
Low – Simplified CDD
Normal – Normal CDD
High – Enhanced CDD
Document reasons for client risk rating:
43
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