I am unable to obtain all the identity of the individuals with senior management position of my corporate customer. Can I just proceed to transact with the corporate customer by obtaining and verifying the ACRA BizFile report only? What if customer refuses to provide his identifying information for customer due diligence?
All Regulated Dealers are required to identify and verify the identity of the customer by obtaining the required information as stipulated in the Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act and Regulations from reliable and independent sources (e.g. ACRA BizFile report or certificate of incorporate or any other corporate documents from reliable and independent sources).
If you are unable to complete customer due diligence, you must not enter into a transaction with that customer and terminate any transaction entered into with that customer. Failure to comply is an offence that is punishable on conviction by a fine not exceeding S$100,000.
MinLaw has provided brochures to help regulated dealers explain their obligations to their customers at http://www.go.gov.sg/acd.
If the customer declines to provide his identifying information you should also consider whether to submit a Suspicious Transaction Report ("STR") to the Suspicious Transaction Reporting Office. Provide a short description of the person, identifiers or any other particulars that you may have and any other documentation that will help us identify him.
A copy of the STR should be submitted to the Anti-Money Laundering/Countering Financing of Terrorism Division of the Ministry of Law (for regulated dealers).
Related questions
Does the Personal Data Protection Act ("PDPA") allow regulated dealers to ask customers for their particulars?
I am a foreign incorporated business/ company/ individual. Do I need to register (e.g. I am the supplier of precious stones and precious metals to a regulated dealer in Singapore. I do not carry out sales in Singapore)?
Whom may I contact to seek clarifications on the Cash Transaction Report (CTR - Form NP 784)?
As a precious stones and precious metals dealer, are there individuals and entities that I am prohibited from dealing with? Where can I find the relevant information / lists of such individuals and entities?
