Approved Trustees – AML/CFT Red Flags

Approved Trustees Related Transactions

1. 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.
2. Subscriptions and/or redemptions by fund managers for a large amount of units in collective investment schemes.
3. Subscriptions and/or redemptions of an unusually large volume by an end investor.

Tax Crimes Related Transactions

1. Negative tax-related reports from the media or other credible information sources.
2. Unconvincing or unclear purpose or motivation for having business relations in Singapore.
3. Business relations managed by external asset managers who may not be adequately regulated and supervised.
4. Purchase or sale of large amounts of precious metals by a customer which is not in line with his business or background.
5. Purchase of bank cheques on a large scale by a customer.
6. 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

1. The customer fails to reasonably justify the purpose of a transaction when queried by the approved trustee.
2. Transactions with countries or entities that are reported to be associated with terrorist activities or with persons that have been designated as terrorists.
3. Frequent changes to the address or authorised signatories.
4. 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.
5. Transactions that are suspected to be in violation of another country’s or jurisdiction’s foreign exchange laws and regulations.