Day 1:
Singapore AML/CFT Laws Applicable to Non-PSPM Luxury Dealers
- Overview of CDSA and TSOFA.
- Key definitions: criminal conduct, property, dealing, and reporting obligations.
- FATF’s expectations for Designated Non-Financial Businesses and Professions (DNFBPs).
- CDSA prosecution involving art and luxury vehicles.
Understanding ML/TF Risks Across Luxury Sectors
- Typologies and red flags: asset-based laundering, resale abuse, nominee transactions, offshore remittance.
- High-risk behaviours: untraceable clients, foreign shell buyers, cash sales
- Business risk assessment and risk mapping - Sector-specific examples:
- Art galleries & antique dealers
- Auction houses and rare collectibles
- Luxury handbag & fashion retailers
- Vintage car and fine wine dealers.
Customer Profiling and Due Diligence Best Practices
- Identifying client risk indicators: nationality, transaction patterns, legal entities.
- Adopting practical CDD practices even without licensing obligations.
- Managing VIPs, foreign buyers, and third-party payers.
Staff Awareness and Operational Controls
- AML/CFT framework – Key compliance areas, establishing SOPs: red flag checklists, transaction logging, basic due diligence forms.
- Building cross-functional accountability across sales, operations, and management.
- Recordkeeping best practices for internal reference and audit trails.
Day 2
Suspicious Transactions & Reporting to STRO
- What counts as suspicious? Indicators in luxury sales environments.
- Filing STRs under CDSA/TSOFA – thresholds, timelines, confidentiality.
- Real-world case: STR filed by an auctioneer dealing in art and vintage watches.
- Draft a STR based on a customer scenario.
Technology, Payments, and Online Risk
- AML risks in online boutiques, cross-border digital payments, and social commerce platforms.
- Third-party platforms and reseller risks (e.g. consignment models, pop-up vendors).
- Use of KYC tools and sanctions screening databases.
- Case discussion: Digital drop shipping and anonymous high-value buyers.
Third-Party Risk and Intermediaries in High-Value Transactions
- AML/CFT risks linked to agents, intermediaries, and resellers.
- Basic due diligence on introducers and consignors.
- Red flags in brokered or referral-based transactions.
Governance, Awareness, and Risk Culture
- Appointing an internal compliance lead – even without regulatory mandate.
- Structuring a basic AML/CFT awareness programme for boutique-level businesses.
- Monitoring, internal audits, and periodic risk assessments.
- Draft an AML checklist for your organisation’s frontline staff.