1.1 Policy Statement
Maju Corporate Service Pte Ltd (“Maju”) is corporate services provider Company to assist our clients on corporate matters. We have legal obligation to have internal policies, procedures and control in place to prevent money laundering and the financing of terrorism.
1.2 Application of a risk-based approach, and identification and assessment of risks
1.2.1 Maju will take reasonable steps to identify and assess its money laundering and financing of terrorism risks and apply a risk-based approach with regard to the following areas:
(a) establishment of internal policies, procedures and controls in order to prevent activities related to money laundering and the financing of terrorism;
(b) identification and verification of identity of beneficial owners;
(c) extent of customer due diligence measures for existing customers and new customers
(d) determining whether to perform enhanced customer due diligence measures or the extent of such measures to be performed for domestic politically exposed persons, politically exposed persons of international organizations, and politically exposed persons who have stepped down, including their immediate family members and close associates, except in cases where the business relationship or transactions with Maju present a high risk for money laundering or the financing of terrorism;
(e) understanding the risks of money laundering and the financing of terrorism in the countries or territories that a third party that the Maju wishes to rely on operates in; and
(g) extent of on-going monitoring.
1.2.2 Maju will take the following steps in order to apply a risk based approach:
(a) Identify the money laundering and financing of terrorism risks that are relevant to it;
(b) Assess the risks identified according to different categories;
(c) Develop different extent of controls to mitigate the assessed risks;
(d) Monitor the implementation of these controls and enhance them if necessary; and
(e) Document the risk assessment, keep it up to date and be able to provide it to ACRA if required.
1.2.3 Maju will identify and assess its relevant money laundering and financing of terrorism financing risks that it potentially faces, and will implement appropriate extent of controls to manage and mitigate the assessed risks. This is subject to any variables in risks that Maju may encounter.
1.3 Development of controls to mitigate money laundering and financing of terrorism risks
1.3.1 In developing controls to mitigate its risks, Maju will perform different extent of customer due diligence measures, and perform different extent of on-going monitoring Maju will have controls:
(a) for the identification and scrutiny of complex or unusually large transactions, unusual patterns of transactions which have no apparent economic or visible lawful purpose and any other activity which Maju regards as particularly likely by its nature to be related to money laundering or the financing of terrorism;
(b) that specify the taking of additional measures, where appropriate, to prevent the development of new products and new business practices, including new delivery mechanisms, for money laundering and the financing of terrorism, and the use of new or developing technologies, for both new and pre-existing products, for money laundering and the financing of terrorism, paying special attention to those that favour anonymity; and
(c) that determine whether a customer, beneficial owner or agent is a politically exposed person during the performance of customer due diligence measures.
1.4 Monitoring effectiveness and enhancement of controls
1.4.1 Maju may consider one or more of the following indicators, or other relevant indicators, in monitoring whether its controls are effective and deciding whether enhancement is needed:
(a) a sudden unaccounted increase in business from an existing customer, for example, the same customer requesting incorporation of many companies;
(b) uncharacteristic transactions which are not in keeping with the customer’s known business activities and profile;
(c) unaccounted peaks of activity at particular locations or at particular times; or
(d) unaccountable or untypical types of customer transactions.
1.4.2 In monitoring the effectiveness of its controls, Maju will consider whether the controls are able to identify any transactions or activities that are unusual or suspicious to Maju.
1.5 Performance of customer due diligence measures
1.5.1 Maju will perform customer due diligence for its customers, beneficial owners and agents by performing the following measures, before it enters into a business relationship with its customers:
(a) identifying the customer and agent and verifying their identities by asking for reliable and independent documents, data or information;
(b) identifying and verifying the identity of any beneficial owner using reasonable measures; and
(c) obtaining information on the purpose and intended nature of any business relationship.
1.5.2 Maju will apply a risk-based approach as described in para. 1.2 to determine the extent of customer due diligence measures that it will perform.
1.5.3 In performing customer due diligence measures, Maju will also take measures to determine whether a customer, beneficial owner or agent is a politically exposed person.
1.5.4 Maju may apply a risk-based approach as described in para.1.2 to determine whether to perform enhanced customer due diligence measures or the extent of such measures to be applied for domestic politically exposed persons, politically exposed persons of international organisations, and politically exposed persons who have stepped down from their prominent public functions, including their immediate family members and close associates, unless the risk of money laundering and the financing of terrorism is high.
1.5.5 If Maju proposes to have a business relationship with a politically exposed person it will perform enhanced customer due diligence measures before it establishes the business relationship.
1.5.6 Maju which has established a business relationship with a politically exposed person will perform enhanced customer due diligence measures and enhanced on-going monitoring over the course of the business relationship.
1.5.7 Maju will perform enhanced customer due diligence measures and enhanced on-going monitoring in other situations where the risk of money laundering and the financing of terrorism is high.
1.5.8 In performing customer due diligence measures, Maju may require its customers and agents to provide their particulars using a “client due diligence acceptance form”, and require the provision of relevant documents and information for verification purposes.
1.5.9 If Maju is unable to perform or complete customer due diligence measures, it will:
(a) not carry out any transaction with or for the customer;
(b) not establish a business relationship with the customer;
(c) terminate any existing business relationship with the customer; or
(d) consider whether it is required to file a suspicious transaction report under section 39(1) of the Corruption, Drug Trafficking and Other Serious Crimes 40 (Confiscation of Benefits) Act; and section 8 or 10 of the Terrorism (Suppression of Financing) Act.
1.6 Filing a suspicious transaction report
1.6.1 Maju will ensure that its team member are trained on its internal reporting procedures and made aware of the persons to whom they have to report, in the event that they detect suspicious activities or transactions concerning money laundering or the financing of terrorism and a suspicious transaction report may have to be filed.
1.6.2 A suspicious transaction report may be made in writing (addressed to Head, Suspicious Transaction Reporting Office), via email to STRO@spf.gov.sg, or via the STR On-Line Lodging System.
1.7 Performance of on-going monitoring of business relationships
1.7.1 Maju will conduct on-going monitoring of a business relationship with a customer. “On-going monitoring” means:
(a) scrutiny of transactions undertaken throughout the course of the relationship (including, where necessary, the source of funds) to ensure that the transactions are consistent with its knowledge of the customer, and its business and risk profile; and
(b) keeping the documents, data or information obtained for the purpose of
applying customer due diligence measures up to date.
1.7.2 Maju will apply a risk-based approach as described in para. 1.2 to decide the extent of on-going monitoring, for example, whether a higher or lower frequency of on-going monitoring is required, and the timing of the on-going monitoring.
1.7.3 When Maju is required to perform enhanced on-going monitoring, it is required to increase the frequency of on-going monitoring over the course of the business relationship concerned.
1.8 Record-keeping
1.8.1 Maju will keep the following records for the entire duration of its business relationship with a customer, and for at least 5 years starting from the date that it ends its business relationship with a customer:
(a) a copy each of the information and evidence of the customer’s and agent’s identity (including that of any beneficial owner in relation to the customer). These include:
(i) copies of all documents used in establishing and verifying the customer’s, beneficial owner’s and agent’s identity;
(ii) the agent’s authority to enter into a business relationship on behalf of a customer;
(iii) information on the purpose and intended nature of the business relationship;
(iv) written records of the basis of Maju’s determination that a customer falls into the categories for which inquiry into the existence of beneficial owner is not required;
(v) documents of [Insert name of registered FA]’s basis for being satisfied that a third party it is relying on to perform customer due diligence has met the legal requirements;
(vi) Maju’s risk assessment where Maju performs simplified customer due diligence measures and the nature of the simplified customer due diligence measures;
(vii) written records of Maju’s findings with regard to a politically exposed person;
(viii) written records of Maju’s findings with regard to other high risk customers or transactions;
(ix) written records of Maju’s measures taken in relation to the screening and training of its team members; and
(b) supporting records.
1.8.2 These records should be sufficient to permit a reconstruction of individual transactions.
1.8.3 Maju has the discretion to keep these records in different formats.
1.9 Screening of team members and training
1.9.1 Maju will:
(
a) implement screening procedures for the hiring of fit and proper persons as its employees;
(b) ensure that its employees are trained on the laws for the prevention of money laundering and the financing of terrorism;
(c) ensure that its employees are trained on prevailing methods of, and trends in, money laundering and the financing of terrorism;
(d) ensure that its employees are trained on its internal policies, procedures and controls for the prevention of money laundering and financing of terrorism, including the roles and responsibilities of officers and employees of the Maju with regard to the implementation of these internal policies, procedures and controls; and
(e) ensure that all records of screening and training are documented.
1.9.2 Maju may consider the following factors when conducting screening of persons who it potentially wishes to hire as employees:
(a) whether the person has been convicted in Singapore, of any offence involving
fraud or dishonesty punishable with imprisonment for 3 months or more;
(b) whether the person is an undischarged bankrupt in Singapore; and
(c) whether, if the person has been previously registered as a FA or qualified
individual, his conduct and compliance history as a registered FA or registered
qualified individual had been satisfactory.
1.10 Audit function, compliance management and internal communication
(a) Maju will implement and maintain an audit function that is independent, and able to regularly assess the effectiveness of the internal policies, procedures and controls for the prevention of money laundering and the financing of terrorism.
(b) Maju will develop compliance management arrangements to continually review and update the internal policies, procedures and controls for the prevention of money laundering and financing of terrorism, and appoint an employer or officer in a management position as the compliance officer in relation to anti-money laundering and countering financing of
terrorism.
(c) Maju will develop internal communication procedures so that its team members, officers and registered qualified individuals are aware of its internal policies, procedures and controls for the prevention of money laundering and financing of terrorism, and their roles in the prevention of money laundering and the financing of terrorism.