Day 1
Singapore’s AML/CFT Legal and Regulatory Landscape
- Overview of CDSA and TSOFA and their relevance to property transactions.
- CEA regulations: Practice Guidelines, CEPCC, and AML/CFT Regulations 2021.
- Role of FATF, STR filing obligations to STRO, and penalties for non-compliance.
- Regulatory action against non-compliant real estate firms and agencies.
Understanding ML/TF Risks in Property Transactions
- Red flags: multiple cash payments, nominee buyers, cross-border remittances.
- Common ML typologies in real estate: value inflation, layering via flipping, misuse of third parties.
- Key Business Line Focus:
- Real Estate Agents / Brokers:
- Risks: Large cash deals, rapid resale, nominee usage, etc.
- Mitigation: Rigorous KYC checks, use of red flag screening tools, transaction monitoring systems.
- Property Development:
Risks: Complex funding layers, opaque investor networks, overseas project flows, etc.
Mitigation: Beneficial ownership tracing, fund source checks, developer-client risk mapping.
- Property Management:
- Risks: Shell tenants, third-party rental payments, diversion of maintenance funds, etc.
- Mitigation: Source of funds verification, rental transaction monitoring, clear audit trails.
- Leasing Business:
- Risks: Complex lease structures, inflated or irregular lease terms, involvement of offshore entities, etc.
- Mitigation: Identity and source verification, sanctions screening, periodic lease portfolio reviews.
Case Exercise: Risk profile different property transaction scenarios.
Customer Due Diligence and Record Keeping Obligations
- CDD, Enhanced CDD (ECDD), ongoing monitoring.
- Collecting and verifying identification and beneficial ownership (BO) details.
- Record-keeping requirements under AML/CFT Regulations.
- Case study: Gaps in client file documentation and missing red flags.
Internal Policies and Staff Responsibilities
- AML/CFT SOPs: CDD forms, red flag checklists, escalation flow.
- Staff training, compliance roles, and internal controls.
- How to respond to suspicious behaviour and protect confidentiality.
- Simulation: Drafting a simple internal escalation memo.
Day 2:
Detecting Suspicious Transactions and Escalation Procedures
- Behavioural indicators: evasiveness, urgency, inconsistent source of funds.
- Escalation pathways and STR reporting process to STRO.
- Documentation and internal review: what to include, timelines, evidence standards.
- Case study: Suspicious buyer profile and transaction structuring.
High-Risk Property Profiles and Red Flags
- Property types commonly abused for laundering (luxury units, unoccupied properties, commercial lots).
- High-risk jurisdictions and third-party agents.
- Use of complex structures, trusts, or offshore entities in deals.
- Case exercise: Flag high-risk transactions in a sample portfolio / transaction.
Technology and Tools for AML/CFT Monitoring in Real Estate
- Use of client risk rating matrices and digital onboarding systems.
- KYC tools, sanctions screening, and transaction alerting.
- Digital signatures and limitations in remote onboarding.
- Case example: Technology-enabled compliance programme for small agency.
Governance, Training and Continuous Compliance
- Senior management and key appointment holder responsibilities.
- Designing training plans and assessing staff awareness
- Monitoring effectiveness of AML/CFT controls through audits and reviews