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. Anna Liow Jin Xiu
  2. Ashleigh Jing Yun Ng
  3. Bernice Yam Hui Xian
  4. Chan Jun Wei
  5. Choi Vanessa
  6. Chong Wei Nian
  7. Chua Keith
  8. Claire Foo
  9. Fang Ian
  10. Goh Jolvin
  11. Ho Marcus
  12. Kantha Rupan S/O Arivalagan
  13. Kar Arpita
  14. Koh Xuan Kai
  15. Lau Chee How
  16. Lek Jing Ting
  17. Leung Daniel
  18. Li Jing
  19. Melissa Lim Seok Tiang (Melissa Lin Shuzhen)
  20. Naomi Chan Mayee
  21. Nathan Khoo
  22. Ng Guanneng
  23. Ong Andrew
  24. Ooi Jin Neng
  25. Poh Cedrick
  26. Siew Carene
  27. Sim Ying Ying
  28. Sow Sean
  29. Tang Sang Thai
  30. Toh Wing Yue Mark Michael
  31. Yee Li Yang
  32. Zhu Jingjing
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