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.
Does the client qualify for any of the exemptions
found in Annex 1 (page 24)?
No
For each beneficial owner that the client has,
complete Form A (pages 9-10).
(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 1516)
Not low risk
Obtain senior management approval using
the form on page 22 prior to completing the
Enhanced CDD form found on page 23
Is there one or more politically exposed
person(s) involved?
No
Conduct risk assessment using the
form found on pages 17-21
Normal
Verify the information obtained using the
enhanced CDD checklist. Upon successful
verification, proceed with client onboarding.
Verify the information obtained using the normal
CDD checklist. Upon successful 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),
both official and any
aliases:
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
owner(s):
Name of person(s)
with executive
authority:
Unique
identification
number:
(Please complete Form A for each beneficial owner.)
(Please complete Form C for each person with executive authority.)
Additional information required
Question
Are you, or any party connected to you, a politically exposed person?
Response
Yes
(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
No
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 WorldCheck, 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
number/incorporation
number:
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
owner(s):
Name of person(s)
with executive
authority:
Country of
incorporation or
registration:
(Please complete Form A for each beneficial owner. Where a beneficial owner cannot be
identified, please complete Form B instead.)
(Please complete Form C for each person with executive authority.)
Additional information required
Question
Are you, or any party connected to you, a politically exposed person?
Response
Yes
(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
No
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 WorldCheck, 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),
both official and any
aliases:
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:
Unique
identification
number:
*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 WorldCheck, 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),
both official and any
aliases:
Contact number(s):
Occupation:
Nationality:
Date of birth:
Residential street
address:
Unique
identification
number:
*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 WorldCheck, 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),
both official and any
aliases:
Contact number(s):
Occupation:
Nationality:
Date of birth:
Residential street
address:
Address of principal
place of business (if
different from above):
Unique
identification
number:
FOR AGENTS WHO ARE LEGAL PERSONS
Full legal name of
registration:
Incorporation
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.
14
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
the client:
Source(s) of wealth:




Self
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
Approximate Amount (SGD)






Select where appropriate
Income
Operating income
From shareholders
From group companies
Investment
Credit facilities
Others (please specify):
Net Worth
Annual
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 WorldCheck, 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):
Routine review of existing client
Response
Yes
No
Review as a result of a trigger event – Please indicate the trigger event:
Yes
For new clients only (leave this field blank if not applicable):
Referred client – Please indicate source of referral below:
Response
Yes
No
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
For new client, up-to-date and relevant client identification information,
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
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
and/or special interest entities in reliable, independent screening
databases5.
Client and connected parties DO NOT MATCH with any of the names
under the list of names under the applicable Schedules of the Terrorism
(Suppression of Financing) Act (Cap. 325) and United Nations
sanctioned entities.
Yes
Response
No
N/A
Yes
No
N/A
Yes
No
Yes
No
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
The ownership of the client is unable to be verified (i.e. comparing
information based on documents).
3
Response
Yes
No
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
6
Client or beneficial owners or directors is a Politically Exposed Person
(PEP).
Client or beneficial owner or directors is matched with a person in the MAS
control list.
Response
Yes
No
Yes
No
The issues are related to predicate crimes for money laundering and/or fraud
and/or crime (including suspected cases).
Yes
No
Client or beneficial owner or connected party has adverse news based on
searches from Factiva and/or Google.
Yes
No
The issues are related to predicate crimes for money laundering and/or fraud
and/or crime (including suspected cases).
Yes
No
Client is involved in High-Risk Industry7.
Client has nominee shareholder/s in the ownership chain where there is no
legitimate rationale.
Yes
Yes
No
No
The nominee shareholder/s represent/s majority ownership
Yes
No
Client is:
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
Singapore (charities.gov.sg/charity/index.do).
Yes
No
Yes
No
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
Client or beneficial owner or beneficiary is connected to high risk
jurisdictions8 in any of the above listed aspects.
Client or beneficial owner or beneficiary is connected to a jurisdiction not in a
9
low risk country .
6
Response
Yes
No
Yes
No
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
Client relationship is established through a non-face-to-face approach.
Client relationship is established through online, postal or telephone, where
non face to face approach is used.
Client relationship is not established through referral.
(where applicable)
Client relationship is established through referral by a member firm in a
jurisdiction that is: ________________________________.
The member firm does not have equivalent AML/CFT measures that are able
to mitigate the risks of being from a higher risk country.
*CDD documents must be obtained from the member firm
Response
Yes
No
Yes
No
Yes
Higher
risk/not in a
low risk
country
Yes
No
Low6
No
“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
or existing client with no previous risk
rating
Section 2 : Justifications
High
Normal
Low
High
Normal
Low
Section 3 : Justifications
Section 4 : Final Risk Rating
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
Source(s) of wealth:
Additional information required for Enhanced CDD
Approximate Amount (SGD)
Select where appropriate
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
Net Worth
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 ;
(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:
11
(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:
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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.
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