SINGAPORE Law and Practice Contributed by: Woon Hum Tan, Shook Lin & Bok LLP
The Licensed FM must perform KYC, AML/CFT, source of funds and source of wealth checks before onboarding a customer. There are also specific requirements for non-face-to-face business relations. All customers of the Licensed FM must be screened and, where screening results in a positive hit against sanctions lists, the Licensed FM must act accord - ingly. This may include freezing, without delay and without prior notice, the funds or other assets of the affected persons and entities that it has control over, so as to comply with applicable laws and regulations in Singapore, including any sanctions. The Licensed FM is subject to the regime that requires them to file a suspicious transaction report to the MAS and the Suspicious Transaction Reporting Office (Singapore’s Financial Intelligence Unit, which is part of the Singa - pore Police Force).
The VCC is subject to a similar AML/CFT and KYC regime but can outsource the function to an eligible financial institution. Typically, this role would be out - sourced to the Licensed FM that launched and man - ages the VCC, as it would have to comply with the AML/CFT and KYC regime in the first place, whether it uses the VCC, another fund structure or a trading account for its customers. 4.12 Data Security and Privacy for Investors The applicable regime in Singapore is too technical and substantive to cover in this chapter. 4.13 Anticipated Changes for Investors There are no forthcoming changes for investors.
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