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Approved Trustees – AML/CFT Red Flags
Approved Trustees Related Transactions
- Transactions are undertaken by fund manager which do not make economic sense, for example, buying and selling of a security with no discernible purpose or in circumstances which appear unusual.
- Subscriptions and/or redemptions by fund managers for a large amount of units in collective investment schemes.
- Subscriptions and/or redemptions of an unusually large volume by an end investor.
Tax Crimes Related Transactions
- Negative tax-related reports from the media or other credible information sources.
- Unconvincing or unclear purpose or motivation for having business relations in Singapore.
- Business relations managed by external asset managers who may not be adequately regulated and supervised.
- Purchase or sale of large amounts of precious metals by a customer which is not in line with his business or background.
- Purchase of bank cheques on a large scale by a customer.
- Extensive or increased use of safe deposit facilities that do not appear to be justified by the background of the customer and for no apparent reason.
Other Types of Transactions
- The customer fails to reasonably justify the purpose of a transaction when queried by the approved trustee.
- Transactions with countries or entities that are reported to be associated with terrorist activities or with persons that have been designated as terrorists.
- Frequent changes to the address or authorised signatories.
- When a person receives funds from a religious or charitable organisation and utilises the funds for the purchase of assets or transfers out the funds within a relatively short period.
- Transactions that are suspected to be in violation of another country’s or jurisdiction’s foreign exchange laws and regulations.