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 2004 and the ACRA (Filing Agents and Qualified Individuals) Regulations 2015.

Name of Appointed Reviewers

  1. Carissa Tan
  2. Claire Foo Xin Rui
  3. Dawn Chiam
  4. Elaine Zhang
  5. Goi Teck Yam
  6. Grace Zhang
  7. Ian Fang Shengyu
  8. Irving Yeo Jun Hui
  9. Janene Cortes
  10. Kantha Rupan S/O Arivalagan
  11. Kar Arpita
  12. Koh Wee Guan
  13. Koh Xuan Kai
  14. Lek Jing Ting
  15. Lem Chin Kok
  16. Lin Yuanzhi
  17. Melissa Ang Jia Hui
  18. Melissa Lim Seok Tiang (Melissa Lin Shuzhen)
  19. Nathan Khoo
  20. Ng Guanneng
  21. Nicholas Koh
  22. Ong Andrew
  23. Ong Ee Chow
  24. Ooi Yong
  25. Qi Heng (Lucas) Tan
  26. Rohit Thadani
  27. Samantha Hui Ling Low 
  28. Sandra Chow Pei San
  29. Serene Teh
  30. Sherlyn Lee Min Hui
  31. Siew Carene
  32. Sow Zhao Sean
  33. Srisuriya Mohan
  34. Tammie Tan
  35. Tan Ann Chi
  36. Tan Rou Jin , Adele
  37. Tan Sang Thai
  38. Toh Wing Yue Mark Michael
  39. Vern Ching
  40. Wang Zheng Rong
  41. Yang Rui
  42. Yeo Kaiting
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