Registered filing agents (“RFA”), are required  to comply with the anti-money laundering and counter terrorism financing requirements which are set out as terms and conditions in the ACRA (Filing Agents and Qualified Individuals) Regulations 2015. To ensure this, ACRA has appointed private sector compliance firms (“Reviewer”) to assist ACRA to perform compliance reviews on RFAs. More information about the Reviewers may be found below. 

RFAs that undergo these compliance reviews will benefit from observations made by the Reviewer so as to make improvements to their anti-money laundering and counter terrorism financing practices. RFAs will also receive a compliance assessment report after the completion of the compliance review.

Scope and methodology of compliance review

The compliance review will include the following areas: 

  • general information about the RFA’s business activities, compliance staff strength and appointment of compliance officer, and overall assessment of its money laundering and terrorism financing risks;
  • the approach that the RFA takes in making risk assessments concerning money laundering and terrorism financing issues;
  • the scope of the RFA’s internal policies, procedures and controls;
  • the customer due diligence and enhanced customer due diligence undertaken by the RFA;
  • the obtaining of beneficial ownership information by the RFA;
  • the ability and turnaround time of the RFA to provide beneficial ownership information to ACRA;
  • suspicious transaction reporting;
  • the internal communication of internal policies, procedures and controls by the RFA; and
  • the scope and frequency of training for the RFA’s employees.

ACRA’s follow up action after the compliance review

Arising from the findings that the Reviewer provided to ACRA, ACRA may require the Reviewer to contact the RFA for follow-up compliance reviews.

ACRA may also deploy its own officers to follow-up with the RFA in writing to address some of the findings that the Reviewer has provided to ACRA or conduct an inspection at the RFA’s premises or to interview the RFA or the persons who represented the RFA during the compliance review by the Reviewer.  ACRA also has the legal powers to impose sanctions on the RFA if it is found to have committed breaches of the ACRA Act and the ACRA (Filing Agents and Qualified Individuals) Regulations 2015.

Information of Reviewers

Compliance Reviewers:

  1. Alan Chew Guo Qiang
  2. Alex Lor Wei Rong
  3. Andrew Ong
  4. Arpita Kar 
  5. Carene Siew Teck Li
  6. Shangari Sivapirakasam
  7. Chan Yun Xian
  8. Charmaine Soh
  9. Chew Jia Xing 
  10. Chong Xue Ian
  11. Dawn Lim Shitian
  12. Eleanor Mak
  13. Giam Ei Leen
  14. Han Shu Ying 
  15. Helen Yoo
  16. Ho Jia Jing
  17. Jeremy Lim Jia Hui
  18. Jolvin Goh Guan Cong
  19. Rishikesa Brahbu Naraya 
  20. Sim Yi Fan
  21. Thomas Liu Zhihua
  22. Vanessa Choi Ai Jia
  23. Xavier Ong Ziheng
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