Implementation Guidance

EP 200 IG 2

Anti-Money Laundering and Countering the Financing

of Terrorism – Requirements and Guidelines for
Professional Accountants in Singapore

Illustrative Customer Due Diligence

Templates

This Implementation Guidance (IG) was issued by the Council of

the Institute of Singapore Chartered Accountants (ISCA) in
November 2015.
 EP 200 IG 2

ANTI-MONEY LAUNDERING AND COUNTERING THE FINANCING

OF TERRORISM – REQUIREMENTS AND GUIDELINES FOR
PROFESSIONAL ACCOUNTANTS IN SINGAPORE

ILLUSTRATIVE CUSTOMER DUE DILIGENCE TEMPLATES

CONTENTS

Pages

Customer Due Diligence Flowchart .................................................................................. 4

Main Form for Natural Persons and Sole Proprietorships ................................................. 56

Main Form for Legal Persons ........................................................................................... 78

Form A for Beneficial Owners .......................................................................................... 910

Form B for Senior Managing Officials 1112

Form C for Individuals with Executive Authority/Agents 1314

Form D for Politically Exposed Persons 1516

Risk Assessment Form .................................................................................................... 1721

Approval Form for High-Risk Engagements 22

Main Form for Higher Risk Clients 23

2
 EP 200 IG 2

Introduction
The Institute of Singapore Chartered Accountants (ISCA) issued the new Ethics Pronouncement (EP)
200, Anti-Money Laundering and Countering the Financing of Terrorism – Requirements and Guidelines
for Professional Accountants in Singapore, in October 2014. This pronouncement has also been adopted
by the Accounting and Corporate Regulatory Authority (ACRA) and is applicable to public accountants
and accounting entities registered under the Accountants Act who are regulated by ACRA.

The comprehensive requirements relating to anti-money laundering (AML) and countering the financing of
terrorism (CFT) contained in the new pronouncement are benchmarked to international best practices
and the latest "International Standards on Combating Money Laundering and the Financing of Terrorism
& Proliferation” issued by the Financial Action Task Force (FATF Recommendations). The
pronouncement was developed by an ISCA Working Group comprising representatives from across the
public accounting sector and in consultation with the relevant regulators such as the Monetary Authority
of Singapore, ACRA and the Commercial Affairs Department of the Singapore Police Force.

With the objective of supporting the accountancy profession to implement the controls and procedures
required in EP 200, ISCA has developed EP 200 Implementation Guidance (IG) 2 – Illustrative Customer
Due Diligence (CDD) Templates to assist professional accountants and professional firms, specifically in
the area of customer due diligence.

The templates and questionnaires provided in EP 200 IG 2 are not prescriptive and should be tailored
and adapted for use, as appropriate for the professional firm’s purposes. Professional firms remain fully
responsible for ensuring compliance with AML and CFT requirements.

3
 EP 200 IG 2

CUSTOMER DUE DILIGENCE (CDD) FLOWCHART AND TEMPLATES AND RISK

ASSESSMENT TEMPLATES

The flowcharts, templates and forms provided in EP 200 IG 2 are illustrations that firms providing the
services listed in paragraph 1.5 of EP 200 may refer to. As they relate to the services listed in paragraph
1.5 of EP 200, the CDD measures are more robust and may be referred to as a best practice guide for
professional firms engaged to perform other types of services. The templates and forms are not
prescriptive and should be tailored and adapted as needed in the professional firm’s professional
judgment. Information for internal office use are marked with the “○” symbol.

The following flowchart illustrates how the CDD process is carried out.

For natural person(s): Complete CDD form

on pages 5-6.
For legal person(s): Complete CDD form on
pages 7-8.

For each beneficial owner that the client has,

No
Does the client qualify for any of the exemptions complete Form A (pages 9-10).
found in Annex 1 (page 24)?
(For legal persons) If no beneficial owner is
identified, complete Form B (pages 11-12)
Yes

For each agent that the client has, complete

Form C (pages 13-14).

Yes
For each PEP, complete Form D (pages 15-
Is there one or more politically exposed 16)
person(s) involved?

No
Obtain senior management approval using
Not low risk the form on page 22 prior to completing the
Conduct risk assessment using the
form found on pages 17-21 Enhanced CDD form found on page 23

Normal

Verify the information obtained using the normal Verify the information obtained using the
CDD checklist. Upon successful verification, enhanced CDD checklist. Upon successful
proceed with client onboarding. verification, proceed with client onboarding.

4
 EP 200 IG 2

MAIN FORM
(For natural persons
and sole
proprietorships)

Information to be Obtained from Client

Information collected in this form should be verified. Verification can be done subsequent to completing
risk assessment.

Identification

FOR NATURAL PERSONS/SOLE PROPRIETORSHIPS ONLY

Full legal name(s), Unique

both official and any identification
aliases: number:
Contact number(s):
Nationality:
Date of birth:
Residential street
address:
Address of principal
place of business (if
different from above):
Intended nature and
purpose of the
business relationship:
Name of beneficial (Please complete Form A for each beneficial owner.)
owner(s):
Name of person(s) (Please complete Form C for each person with executive authority.)
with executive
authority:

Additional information required

Question Response
Are you, or any party connected to you, a politically exposed person? Yes No
(Please complete
Form D for each
PEP)
What country is your business based in?
What type of products does your business sell or manufacture?
Please provide further details in the box below if necessary.
Any further details:

5
 EP 200 IG 2

MAIN FORM
(For natural persons
and sole
proprietorships)

Client/Agent’s Declaration

I declare that the information provided in these forms is true and correct. I am aware that I may be subject
to prosecution and criminal sanctions under written law if I am found to have made any false statement
which I know to be false or which I do not believe to be true, or if I have intentionally suppressed any
material fact.

Name of client/agent:
Identity/passport number:
Date:
Signature:

○ Verification (for office use)

Professional judgment must be exercised in determining if verification of identity should be that of “Normal
CDD” or “Enhanced CDD” standards, depending on the risk assessment performed on the client.

For Normal CDD, the following documents can be used to verify the client’s identity:

Copy of screening results from a reliable independent database (e.g., Thomson Reuters World-
☐
Check, Dow Jones Risk and Compliance database) of the client

Copy of passport or identification card (for Singaporeans and Singaporean Permanent Residents
☐
only)

A document containing the address of the individual (e.g., a bank statement or a recent utility bill) ☐

6
 EP 200 IG 2

MAIN FORM
(For legal persons)

Information to be Obtained from the Client

Identification

FOR LEGAL PERSONS ONLY

Full legal name of

registration:
Contact number(s):
Business type: Partnership / Limited Liability Partnership / Corporation*

Other:
*delete where inapplicable
Registration Country of
number/incorporation incorporation or
number: registration:
Registered address:
Address of principal
place of business (if
different from above):
Intended nature and
purpose of the
business relationship:
Names of the directors
or partners:
Name of beneficial (Please complete Form A for each beneficial owner. Where a beneficial owner cannot be
owner(s): identified, please complete Form B instead.)

Name of person(s) (Please complete Form C for each person with executive authority.)
with executive
authority:

Additional information required

Question Response
Are you, or any party connected to you, a politically exposed person? Yes No
(Please complete
Form D for each
PEP)
What country is your business based in?
What type of products does your business sell or manufacture?
Please provide further details in the box below if necessary.
Any further details:

7
 EP 200 IG 2

MAIN FORM
(For legal persons)

Client/Agent’s Declaration

I declare that the information provided in these forms is true and correct. I am aware that I may be subject
to prosecution and criminal sanctions under written law if I am found to have made any false statement
which I know to be false or which I do not believe to be true, or if I have intentionally suppressed any
material fact.

Name of client/agent:
Identity/passport number:
Date:
Signature:

○ Verification (for office use)

Professional judgment must be exercised in determining if verification of identity should be that of “Normal
CDD” or “Enhanced CDD” standards, depending on the risk assessment performed on the client.

For Normal CDD, the following documents can be used to verify the client’s identity:

Copy of screening results from a reliable independent database (e.g., Thomson Reuters World-
☐
Check, Dow Jones Risk and Compliance database) of the client

Memorandum and Articles of Association ☐

ACRA profile of the company or incorporation or registration documents from a regulatory body (for
☐
foreign firms) or certificate of incorporation (for foreign firms)

Information documenting the ownership and control structure of the entity (e.g., ownership chart
☐
signed by a director.)

8
 EP 200 IG 2

FORM A
(Identification and
verification of
beneficial owners)
Form A: Beneficial Owners

For each beneficial owner that the client has, please complete the following form. Certain clients do not
need to fill up this form. Please refer to Annex 1 for a list of these clients.

If an ACRA search profile of the shareholders have been obtained, it is not necessary to verify the identity
of the shareholders/partners further. A shareholder may be a beneficial owner if the shareholder
ultimately owns or controls more than 25% of shares in the company.

Identification

BENEFICIAL OWNER

Full legal name(s), Unique

both official and any identification
aliases: number:
Contact number(s):
Occupation:
Nationality:
Date of birth:
Residential street
address:
Information regarding
the nature of beneficial
ownership and the
ownership and control
structure of the client:

*If the beneficial owner is a PEP, Form D must be completed in addition to this form.

Client/Agent’s Declaration

I declare that the information provided in these forms is true and correct. I am aware that I may be subject
to prosecution and criminal sanctions under written law if I am found to have made any false statement
which I know to be false or which I do not believe to be true, or if I have intentionally suppressed any
material fact.

Name of client/agent:
Identity/passport number:
Date:
Signature:

9
 EP 200 IG 2

FORM A
(Identification and
verification of
beneficial owners)
○ Verification (for office use)

Verification of the identity of beneficial owners is to be done on the basis of risk. Reasonable measures
should be taken to verify the identity of the beneficial owners. For example, the following documents can
be collected:

Copy of screening results from a reliable independent database (e.g., Thomson Reuters World-
☐
Check, Dow Jones Risk and Compliance database) of the beneficial owner

Copy of passport or identification card (for Singaporeans and Singaporean Permanent Residents
☐
only)

10
 EP 200 IG 2

FORM B
(For senior
managing officials)
Form B: Senior Managing Officials

In the event that no natural persons are identified as the beneficial owners, this form should be completed
to identify and verify the identity of the relevant natural person(s) holding the position of senior managing
official(s).

Identification

SENIOR MANAGING OFFICIAL 1

Full legal name(s), Unique

both official and any identification
aliases: number:
Contact number(s):
Occupation:
Nationality:
Date of birth:
Residential street
address:

*If the senior managing offical is a PEP, Form D must be completed in addition to this form.

Client/Agent’s Declaration

I declare that the information provided in these forms is true and correct. I am aware that I may be subject
to prosecution and criminal sanctions under written law if I am found to have made any false statement
which I know to be false or which I do not believe to be true, or if I have intentionally suppressed any
material fact.

Name of client/agent:
Identity/passport number:
Date:
Signature:

11
 EP 200 IG 2

FORM B
(Senior managing
officials)

○ Verification (for office use)

Verification of the identities of senior managing officials is to be done on the basis of risk. Reasonable
measures should be taken to verify the identity of the beneficial owners. For example, the following
documents can be collected:

Copy of screening results from a reliable independent database (e.g., Thomson Reuters World- ☐
Check, Dow Jones Risk and Compliance database) of the senior managing official
Copy of passport or identification card (for Singaporeans and Singaporean Permanent Residents ☐
only)

12
 EP 200 IG 2

FORM C
(Agents)

Form C: Individuals with Executive Authority/Agents

Where a person purports to act on behalf of a client, the professional firm shall identify and verify the
identity of the person and shall verify that the person is so authorised by completing this form.

Identification

FOR AGENTS WHO ARE INDIVIDUALS ONLY

Full legal name(s), Unique

both official and any identification
aliases: number:
Contact number(s):
Occupation:
Nationality:
Date of birth:
Residential street
address:
Address of principal
place of business (if
different from above):

FOR AGENTS WHO ARE LEGAL PERSONS

Full legal name of Incorporation

registration: number or
registration
number:
Contact number(s):
Place of incorporation
or registration:
Date of incorporation
or registration:
Registered address:
Address of principal
place of business (if
different from above):

*If the agent is a PEP, Form D must be completed in addition to this form.

13
 EP 200 IG 2

FORM C
(Agents)
Client/Agent’s Declaration

I declare that the information provided in these forms is true and correct. I am aware that I may be subject
to prosecution and criminal sanctions under written law if I am found to have made any false statement
which I know to be false or which I do not believe to be true, or if I have intentionally suppressed any
material fact.

Name of client/agent:
Identity/passport number:
Date:
Signature:

○ Verification (for office use)

The authority of an agent to act on behalf of the client shall be verified. This may be done by obtaining
documentary evidence that the client has appointed the agent to act on his behalf or a summary of the
oral instructions given to the agent by the client; and the specimen signatures of the person appointed.

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 EP 200 IG 2

FORM D
(PEP)

Form D: Politically Exposed Persons (PEPs)

Where there is one or more PEPs involved, this form must be completed. Please use a separate form for
each PEP.

Identification

FOR POLITICALLY EXPOSED PERSON(S) ONLY:

Name of PEP:
Nature of prominent
public function that the
PEP is or has been
entrusted with1:
Name of public
function:
Country:
Period of service:
PEP relationship with  Self
the client:  Family member (Spouse / Child / Parent / Child’s Spouse*)
 Close associate
 Ultimate beneficial owner / shareholder / director / partner / authorized
person* of client
 Others (please specify):
*delete where inapplicable
Source(s) of wealth: Approximate Amount (SGD)

Select where appropriate Net Worth Annual

Income
 Operating income
 From shareholders
 From group companies
 Investment
 Credit facilities
 Others (please specify):
Source of funds:

1
For example, as a domestic politically exposed person, a foreign politically exposed person, or a politically exposed person of an
international organisation.

15
 EP 200 IG 2

FORM D
(PEP)

Client/Agent’s Declaration

I declare that the information provided in these forms is true and correct. I am aware that I may be subject
to prosecution and criminal sanctions under written law if I am found to have made any false statement
which I know to be false or which I do not believe to be true, or if I have intentionally suppressed any
material fact.

Name of client/agent:
Identity/passport number:
Date:
Signature:

○ Verification (for office use)

Documents required for verification
Copy of screening results from a reliable independent database (e.g., Thomson Reuters World- ☐
Check, Dow Jones Risk and Compliance database) of the PEP
A document containing the address of the PEP (e.g., a bank statement or a recent utility bill) ☐
Documents verifying the source of funds and wealth2 ☐
Copy of passport or identification card (for Singaporeans only) ☐
Any published convictions, penalties and sanctions involving the PEP ☐

2
Examples of independent verification measures include citing public information sources (e.g. company websites, corporate
registration websites, journals and media reports) to verify net worth as well as obtaining documentary evidence, such as bank
statements, confirmation from third party professionals (e.g. tax advisors), and financial statements or management accounts of
operating companies. Professional firms should also assess the authenticity and reliability of the documents provided by the
clients. More evidentiary verification options are typically required for higher-risk clients. Aside from the common verification
measures such as citing public information sources, some institutions commission independent investigations to perform
background checks on higher-risk PEPs, obtain financial statements of the business(es) where the source of wealth/funds is
derived, and perform site visits.

16
 EP 200 IG 2

Anti-Money Laundering / Countering the Financing of Terrorism (AML/CFT)

Risk Assessment Form

For existing clients only (leave this field blank if not applicable): Response
Routine review of existing client Yes No

Review as a result of a trigger event – Please indicate the trigger event: Yes No

For new clients only (leave this field blank if not applicable): Response
Referred client – Please indicate source of referral below: Yes No

3
Please provide details regarding the nature of services required by client :

Establishing or continuing business relationship with the client is NOT allowed if the answer to
any of the questions below is "NO."

Question Response
For new client, up-to-date and relevant client identification information, Yes No N/A
including information on shareholders and directors, has been obtained
as per Page 1.

For existing client, no doubt arises as to the veracity or adequacy of the Yes No N/A
evidence previously obtained for the purposes of client identification;
otherwise, client identification information has been re-verified.
4
Client and connected parties DO NOT MATCH with terrorist suspects Yes No
and/or special interest entities in reliable, independent screening
databases5.
Client and connected parties DO NOT MATCH with any of the names Yes No
under the list of names under the applicable Schedules of the Terrorism
(Suppression of Financing) Act (Cap. 325) and United Nations
sanctioned entities.

If the answer to any of the following questions is "Yes”, the business relationship must be either
terminated or declined. If the answer is “No”, the risk level is “Normal” and you may proceed to
the risk assessment questionnaire.

Question Response
The ownership of the client is unable to be verified (i.e. comparing Yes No
information based on documents).

3
Certain services are subject to additional requirements under the Ethics Pronouncement 200 and CSP Guidelines. Pl ease see
Annex 2 for a list of these services.
4
Connected parties may be family members or close associates (e.g. individuals closely connected either socially or profession ally).
5
Possible databases you may use are Accuity Compliance, Thomson Reuters W orld-Check, Dow Jones Risk & Compliance
Database and Truth Technologies’ Sentinel.

17
 EP 200 IG 2

Risk Assessment Questionnaire

Section 1: Client background

Question Response
6
Client or beneficial owners or directors is a Politically Exposed Person Yes No
(PEP).
Client or beneficial owner or directors is matched with a person in the MAS Yes No
control list.

The issues are related to predicate crimes for money laundering and/or fraud Yes No
and/or crime (including suspected cases).

Client or beneficial owner or connected party has adverse news based on Yes No
searches from Factiva and/or Google.

The issues are related to predicate crimes for money laundering and/or fraud Yes No
and/or crime (including suspected cases).

Client is involved in High-Risk Industry7. Yes No

Client has nominee shareholder/s in the ownership chain where there is no Yes No
legitimate rationale.

The nominee shareholder/s represent/s majority ownership Yes No

Client is: Yes No

- a shell company or has complex shareholding structure (e.g.,
involving 3 layers or more of ownership structure, different
jurisdictions, trusts); AND
- without an obvious commercial purpose.
Client is a charitable or non-profit organization that is NOT registered in Yes No
Singapore (charities.gov.sg/charity/index.do).

Section 2: Client Location

Please consider as applicable: Client nationality; Place of formation/incorporation; Residential address;

Permanent address; Place of operation; Place where business is established.

Question Response
Client or beneficial owner or beneficiary is connected to high risk Yes No
jurisdictions8 in any of the above listed aspects.
Client or beneficial owner or beneficiary is connected to a jurisdiction not in a Yes No
9
low risk country .

6
A beneficial owner refers to the natural person who ultimately owns or controls a client and/or the natural person on whose behalf
a transaction is being conducted. It also includes those persons who exercise ultimate effective control over a legal person or
arrangement.
7
As determined by the firm, such as with reference to publications and guidance issued from time to time by the FATF.
8
Refer to the FATF list of high-risk and non-cooperative jurisdictions to determine which countries are high-risk jurisdictions:
http://www.fatf-gafi.org/topics/high-riskandnon-cooperativejurisdictions/
9
Determining whether a country is low-risk should be based on the firm’s internal policy and your professional judgment. Reference
should be made to the FATF list of high-risk countries as well.

18
 EP 200 IG 2

Section 3: Client Meeting

Question Response
Client relationship is established through a non-face-to-face approach. Yes No
Client relationship is established through online, postal or telephone, where Yes No
non face to face approach is used.
Client relationship is not established through referral. Yes No
(where applicable) Higher Low6
Client relationship is established through referral by a member firm in a risk/not in a
jurisdiction that is: ________________________________. low risk
country
The member firm does not have equivalent AML/CFT measures that are able Yes No
to mitigate the risks of being from a higher risk country.
*CDD documents must be obtained from the member firm

“Yes” to any of the questions in Sections 1, 2 and 3 serves as an indicator of higher risk. Where there is
one or more “yes” responses, professional judgment, with reference to the policies and procedures of the
professional firm, must be exercised as to the nature of the Customer Due Diligence to be carried out.

Please discuss any risk factor with the Money Laundering Reporting Officer (MLRO).

The following is only where the client is, or is associated with, a PEP.

PEP risk factors:

 Expected receipt of large sums from governmental bodies or state-owned entities

 Source of wealth described as commission earned on government contracts
 Request to associate any form of secrecy with a transaction
 Use of accounts at a government-owned bank or government account as source of funds
 None of the above
 Other (please specify):

19
 EP 200 IG 2

Section 4: Risk Evaluation

Initial CDD procedures should be conducted as follows:

- “Low” risk rating: Simplified CDD should be performed.
- “Normal” risk rating: Normal CDD should be performed.
- “High” or “Medium” risk rating: Enhanced CDD should be performed.

The following risk evaluation is to assist in determining what level of ongoing monitoring and CDD should
be conducted.

Instructions
1. Obtain an initial risk rating, being the highest risk indicator in Section 1.
2. Provide justifications in Section 2 to adjust the initial risk rating in Section 1, if considered justifiable,
subject to the following conditions:
 High risk rating should NOT be reduced if Client is attached to any of the following risk factors:
Section 1 : PEP, Section 2 : High-Risk Jurisdictions
 Justifications must also be provided for adjustment from High-Risk to Low-Risk in Section 3

Section 1 : Current risk rating of existing

client; OR Initial risk rating for new client High Normal Low
or existing client with no previous risk
rating
Section 2 : Justifications

Section 3 : Justifications

Section 4 : Final Risk Rating

High Normal Low

Section 4 is to be signed off by the Money Laundering Reporting Officer (MLRO) if it differs from
Section 1.

The final risk rating may be used as a guide to the level of ongoing monitoring that the client should be
subject to. This only serves as a guide and professional judgment should still be exercised in deciding on
the appropriate level of ongoing monitoring and CDD processes.

20
 EP 200 IG 2

Section 5: Recommendation

Additional approvals may be needed for higher-risk factors.

Business relationship Establish Maintain Decline Terminate

“Terminate” action should be discussed with the MLRO to decide appropriate further action.

Assessed by:

Signature: _____________________________ Date: _____________________________

Name: _______________________________ Position: ____________________________

Approved by:

Signature: _____________________________ Date: _____________________________

Name: _______________________________ Position: ____________________________

21
 EP 200 IG 2

○ Approval Form for High-Risk Engagements

In the event of high-risk engagements, senior management approval shall be obtained before establishing
(or continuing, for existing clients) the business relationship. Subsequent to senior management
approval, enhanced CDD shall be conducted.

Engagement Information
Description of
engagement:

Engagement
team members:

Client Information
Client name:

Registration
number:

Country of
incorporation:

Date of
incorporation:

Address:

Contact number:

Senior Management Approval

I approve the above engagement. The team may proceed with the engagement provided that enhanced
CDD is successfully conducted.

Signature: _____________________________ Date: _____________________________

Name: _______________________________ Position: ____________________________

22
 EP 200 IG 2

MAIN FORM
(For higher-risk
clients only)

Enhanced Customer Due Diligence

Additional information required for Enhanced CDD

Source(s) of wealth: Approximate Amount (SGD)

Select where appropriate Net Worth

Annual Income
 Operating income
 From shareholders
 From group companies
 Investment
 Credit facilities
 Others (please specify):
Source of funds:

Background and
purpose of any
transaction(s) that the
firm has been engaged
to carry out:
Any other additional
information:

23
 EP 200 IG 2

Annex 1
Unless the professional firm has doubts about the veracity of the CDD information obtained or suspects
that the client, business relations with, or transaction for the client may be connected with money
laundering or terrorist financing activities, it is not necessary for the professional firm to identify and verify
the identity of any shareholder or beneficial owner of a client if the client is:.
10
(a) A Singapore Government entity ;
11
(b) A foreign government entity ;

(c) An entity listed on the Singapore Exchange;

(d) An entity listed on a stock exchange outside of Singapore that is subject to regulatory disclosure
requirements (e.g., the foreign stock exchanges of FATF member countries);

(e) A majority-owned subsidiary of a company in (c) or (d);

(f) A financial institution that is licensed, approved, registered (including a fund management company
registered under paragraph 5(1)(i) of the Second Schedule to the Securities and Futures (Licensing
and Conduct of Business) Regulations (Rg. 10)) or regulated by the MAS but does not include:

(i) Holders of stored value facilities, as defined in section 2(1) of the Payment Systems
(Oversight) Act (Cap. 222A); and

(ii) A person (other than a person referred to in (g) and (h)) who is exempted from licensing,
approval or regulation by the MAS under any Act administered by the MAS, including a
private trust company exempted from licensing under section 15 of the Trust Companies Act
(Cap. 336) read with regulation 4 of the Trust Companies (Exemption) Regulations (Rg. 1);

(g) A person exempted under section 23(1)(f) of the Financial Advisers Act (Cap. 110) read with
regulation 27(1)(d) of the Financial Advisers Regulation (Rg. 2);

(h) A person exempted under section 99(1)(h) of the Securities and Futures Act (Cap. 289) read with
paragraph 7(1)(b) of the Second Schedule to the Securities and Futures (Licensing and Conduct of
Business) Regulations;

(i) A financial institution incorporated or established outside Singapore that is subject to and
supervised for compliance with AML/CFT requirements consistent with standards set by the FATF;
or

(j) An investment vehicle where the managers are financial institutions:

(i) Set out in (f)-(h) above; or

(ii) incorporated or established outside Singapore but are subject to and supervised for
compliance with AML/CFT requirements consistent with standards set by the FATF,

10
Singapore Government entities include the Singapore Government, the Ministries, statutory boards, organs of state and other
organisations as set out in the Singapore Government Directory.
11
A foreign government entity means a government of a foreign country or jurisdiction, a ministry within such a government, or an
agency specially established by such a government through written law.

24
 EP 200 IG 2

Annex 2

The following services must comply with Section 4 of the Ethics Pronouncement 200:

 Buying and selling of real estate;

 Managing of client money, securities or other assets;
 Management of bank, savings or securities accounts;
 Organisation of contributions for the creation, operation or management of companies;
 Creation, operation or management of legal persons or arrangements, and buying and selling of
business entities.

Corporate service providers are required to comply with Part II of the First Schedule of the Accounting
and Corporate Regulatory Authority (Filing Agents and Qualified Individuals) Regulations 2015, entitled
“Anti-Money Laundering and Anti-Terrorism Financing Measures”. Entities providing these services fall
under corporate service providers:

 Formation of corporations or other legal persons;

 Providing a registered office, business address or correspondence or administrative address or
other related services;
 Acting, or arranging for another person to act as a partner of a partnership;
 Acting, or arranging for another person to act in a position similar to the above in relation to other
legal persons;
 Acting, or arranging for another person to act as director or secretary of a corporation;
 Acting, or arranging for another person to act, as a shareholder on behalf of any corporation other
than one whose securities are listed on a securities exchange under section 2(1) or recognized
securities exchange under section 283(1) of the Securities and Futures Act.

25