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