Use the form before onboarding and verify the information
CDD helps distinguish unusual or suspicious behaviour from expected customer activity. The common form can support both audit firms and corporate service providers, including historical RFAs and RQIs, before establishing relations. Information should be checked against independent or reliable sources and screening evidence retained. A completed form can streamline shared information, but each intermediary remains fully responsible for compliance and must tailor it to the business. The source is explicitly updated 1 July 2023 and refers to the 2023 accountant AML rules and 2015 filing-agent regulations; its dates and legal categories should be preserved rather than silently presented as a complete current regime.
Screen all relevant people and clear alerts with evidence
Screen the client, appointed natural person acting for it, connected parties and beneficial owners for sanctions and money-laundering or terrorism information, including MAS and MHA lists. Screening also covers adverse media, criminal activity, corruption, drug trafficking and PEP links. Commercial tools are encouraged and public searches may be used, but the intermediary must retain results and document how alerts are satisfactorily cleared. Merely checking a sanctions list is insufficient. Under the bulletin, audit firms use SONAR for STRs; paper filings must be refiled electronically. SONAR also covers cross-border cash reports NP728 and precious-stones/metals cash reports NP784. Non-compliance can attract Part 5A sanctions, without the source specifying a single penalty amount.
Part 1 A1: individuals, agents and connected parties
Record capacity, full name and aliases, residence, NRIC/passport/FIN and expiry where applicable, birth date, gender, nationalities, international-format phone and email, and the intended service relationship. Connected parties include natural persons with executive authority, such as directors, managing directors, partners and CEOs. Evidence of an agent’s authority may be a board resolution or power of attorney. Duplicate the section for each relevant person. The asterisks identify specified required information in the cited regulations; they do not mean unstarred fields are always irrelevant. A client or the person supplying information on its behalf may sign: signatures from every director or beneficial owner are not required by this form.
Part 1 A2: entity information and business context
For an existing or proposed entity, obtain its name, former and trading names, UEN, registered or intended office, different principal business address, registration or proposed country and date, phones, email, nature of business and main transaction countries. List all directors or partners as connected parties and collect their A1 details. RFAs should obtain information about the proposed entity for which transactions are performed. Proposed status is not a reason to leave the ownership, service purpose or authority unexplained.
Part 1 B: identify ultimate owners and control
The form first asks who ultimately owns assets or undertakings, alone or together. Where that is doubtful or no such natural owner exists, identify ultimate effective or significant control; where neither route identifies a natural person, identify executive-authority holders or equivalent positions. Record each owner’s name, aliases, residence, nationality, identification and expiry, birth date, phone and email, the nature of ownership or authority and the ownership/control structure. More-than 25% ownership is given as an example field description, not a complete standalone test replacing the broader identification sequence. Repeat for multiple owners and screen PEP status.
Part 1 C–E: PEPs, wealth, funds and declaration
The form covers current and former prominent public functions in Singapore, abroad or international organisations, and family or close associates. Record the category, relationship where relevant, PEP name, country or organisation, function and tenure; omit SectionC only where no PEP exists. Higher risk calls for wealth and relationship-funds information and any further necessary details. Examples are foreign PEPs and their family/associates, high-risk domestic or international-organisation PEPs and related persons, and other high-risk individuals. If enhanced CDD is considered unnecessary, document the assessment and reasons. SectionE records the provider’s true-and-correct declaration, identification, date and signature. Wealth and funds are separate questions, not interchangeable labels.
Part 2 A: identify all service types
The internal risk form expressly includes ML, TF and proliferation-financing risks. Its eleven service categories are forming entities; acting or arranging directors, secretaries, partners or equivalent roles; nominee-shareholder arrangements with the stated listed-securities exclusions; registered-office and related addresses; real-estate transactions; client money, securities or assets; bank, savings or securities accounts; organising company contributions; buying or selling entities; statutory audits; and other services such as annual returns. The source cites SFA sections 2(1) and 283(1) for the nominee-shareholder exclusion. The service checklist describes form coverage, not a complete claim that every listed service has identical legal duties.
Part 2 B1: the full customer-risk checklist
The eighteen numbered questions, with 4a/4b split, cover new clients; listing without disclosure requirements; asset-holding legal entities; nominees and nominee-majority ownership; unusual complexity; cash-intensive activity; unexplained repeated cash; fraud/dishonesty convictions; PEPs; outdated accounts; frequent ownership/director changes and their reasonableness; information difficulties; independent verifiability; foreign-unregistered charities/nonprofits; shell companies; high-risk industries; adverse screening; and unresolved exceptions. The source advises risk-sensitive enhanced CDD where a majority receive yes, but some questions are positively framed, including whether information can be verified. Do not convert this illustrative form into an automatic numeric score. The list is non-exhaustive, and serious individual indicators remain relevant.
Part 2 B2–B3: country and transaction factors
Country factors consider nationality, incorporation, residences, operations and establishment. Five questions concern weak AML/CFT regimes, dealings with high-risk jurisdictions, regulatory sanctions such as UN sanctions, terrorist support or organisations, and FATF countermeasures. Any yes prompts the source’s enhanced-CDD advice. Nine transaction questions cover anonymity, funds without an underlying service, unexplained patterns or large cash, unknown third-party payments, nominee shells, commercially unexplained entity purchases or multi-country structures, relationships and transactions without physical meetings, and inconsistency with the known profile. A majority yes prompts advice, not an exhaustive legal safe harbour. The FATF, MAS and MHA references are sources to consult; the PDF does not supply a permanent country blacklist.
Final rating, recommendation and approval
Record low, medium or high risk with reasons, an acceptance recommendation with officer identity, role, date and signature, and a separate approval decision with equivalent details. Attach reasons for accepting high-risk clients and where approval contradicts the recommendation. The footnote recommends separating assessment and approval duties as good practice. A rejection or non-recommendation may need escalation to compliance or senior management and/or an STR where necessary; it does not mean every refusal automatically requires an STR. Blank fields and example checklist answers are not evidence of actual diligence: retained verification, alert resolution and reasoned decisions complete the process.
Official source
This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.
Read the official PDF ↗