Corporate Service Providers – AML/CFT Red Flags

Incorporation of shell companies

1. Companies registered in Singapore with no apparent business and low paid up capital.
2. Addresses of the Filing Agent (FA) or Post Office (P.O.) box addresses are used by the companies as their registered/mailing addresses.
3. Multiple bank accounts opened with various banks for no apparent economic or business reason.
4. Authorised bank signatories are usually foreign directors and shareholders are located overseas.
5. Bank accounts are opened at around the same period foreign directors are in Singapore to incorporate their companies.
6. Bank accounts are opened at around the same period foreign directors are in Singapore to incorporate their companies.
7. Frequent large incoming remittances into bank accounts from different individuals and companies, located mainly overseas.
8. After receipt of funds in the bank accounts, the funds are usually moved out of Singapore within the next few days. These bank accounts generally have low balances.
9. Transaction patterns in the bank accounts are often not in line with the company’ principal business.

Indicators relating to other crimes

1. Clients give false/misleading explanation for Customer Due Diligence (“CDD”) purposes.
2. Clients unwilling/unable to provide information for CDD purposes.
3. Clients use forged/fraudulent/ false identity documents for CDD purposes.
4. Clients uncontactable for CDD purposes.
5. Clients featured in news adversely.
6. Suspicious transactions involving entities involved in sensitive employment/responsibility.
7. FA suspects client is a Political Exposed Persons.
8. Unrealistic turnover in client’s business accounts.
9. Unusual/ uneconomical movement of funds.