Anti-Money Laundering and Counter Financing of Terrorism

Under Section 39(1) of the CDSA, it is mandatory for a person to lodge a Suspicious Transaction Report with the Suspicious Transaction Reporting Office when, in the course of his trade, profession, business or employment, he knows or has reason to suspect that any property, directly or indirectly, represents proceeds of drug dealing or criminal conduct or was used/is intended to be used in connection with drug dealing or criminal conduct.

Find out more information on CDSA.

Under sections 3, 4, 5 and 6 of the TSOFA:

All persons shall not provide, use, possess or collect property, or make available any financial or other related services if they know or have reasonable grounds to believe that such property or services are to be used for terrorist acts or purposes, or to benefit any terrorist or terrorist entity; and

All persons shall not deal in any terrorist’s property. This includes entering into or facilitating any financial transaction relating to a dealing in such property, or providing any financial services or any other related services in respect of such property, knowing or having reasonable grounds to believe that the property is owned or controlled by or on behalf of any terrorist or terrorist entity, including funds derived or generated from property owned or controlled by any terrorist or terrorist entity.

Find out more information on TSOFA. 

There are prohibitions against dealing, directly or indirectly, in any property owned or controlled by or on behalf of

• who a designated person;
• any entity or individual who acts on behalf of or under the direction of a designated person; or
• any entity owned or controlled by a designated person.

These designated person are subject to travel ban and asset freeze due to their involvement in proliferation of weapons of mass destruction and its financing.

You are required to screen prospective purchasers against publicly available lists before the issue of any Option to Purchase.

Find out more information on the United Nations Act.

Screening

Under the UN Regulation:

To ensure compliance with the CDSA, TSOFA and the United Nations Act, before the issue of any Option to Purchase, developers should screen their prospective purchasers against the following publicly available lists of individuals and entities:

• Consolidated United Nations Security Council Sanctions List
• MAS’ Lists of Designated Individuals and Entities

Developers are encouraged to refer and subscribe to the websites below for updates:

• Inter-Ministry Committee on Terrorist Designation website for information on terrorist designation and requirements for countering the financing of terrorism
• MAS’s website on targeted financial sanctions under the UN Regulations