Wolfline Capital Pte. Ltd. (“Wolfline Capital”) is committed to conducting business with integrity and to mitigating risks relating to money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud, bribery, corruption and other financial crime.
Wolfline Capital applies a risk-based approach that is proportionate to the nature of its corporate finance, capital markets, M&A advisory and transaction-coordination activities.
Depending on the nature, jurisdiction and risk profile of a proposed engagement, Wolfline Capital may request and assess information relating to:
the identity of the client, its directors, authorised representatives and beneficial owners;
the client’s business activities, ownership and control structure;
the purpose and expected nature of the engagement or transaction;
relevant jurisdictions, counterparties and transaction flows;
source of funds and, where appropriate, source of wealth;
sanctions, politically exposed person (PEP) and adverse-media screening; and
any other information reasonably required to understand and manage financial-crime risk.
Wolfline Capital may refresh due diligence during an engagement where circumstances, ownership, counterparties, jurisdictions or other relevant risk factors change.
Wolfline Capital seeks to comply with sanctions requirements that are legally applicable to it and to the relevant engagement. As part of its risk framework, Wolfline Capital may also consider sanctions measures and restrictions issued by the United Nations, Singapore and other relevant jurisdictions where these are material to a transaction, counterparty or service provider.
Wolfline Capital will not knowingly facilitate a transaction intended to evade applicable sanctions or other legal restrictions.
Wolfline Capital may coordinate with external lawyers, accountants, auditors, registrars, paying and settlement agents, placement agents, banks, market infrastructure providers and other professional counterparties. Each third party remains responsible for its own regulatory, legal, compliance and onboarding obligations.
Wolfline Capital may require additional documentation where a transaction involves higher-risk jurisdictions, complex ownership structures, unusual payment flows, sensitive industries or other heightened risk factors.
Certain activities, including securities placement, solicitation, dealing or other financial-services activities, may be regulated in particular jurisdictions. Where applicable, such activities are conducted by appropriately authorised or exempt third-party intermediaries or otherwise in accordance with applicable law. The precise scope of Wolfline Capital’s role is defined in the relevant engagement documentation.
Wolfline Capital does not offer deposit-taking services and does not accept deposits from the public.
Wolfline Capital reserves the right to request additional information, pause onboarding, decline an engagement, suspend work or terminate a relationship where information is incomplete, inconsistent or gives rise to legal, sanctions, financial-crime, reputational or other material risk concerns.
Where required by applicable law, Wolfline Capital may make disclosures or reports to competent authorities and may be restricted from informing the relevant person about such action.
Wolfline Capital maintains internal records and procedures appropriate to its business and periodically reviews its financial-crime controls. Relevant personnel are expected to escalate material compliance concerns and to complete appropriate compliance training.
Questions concerning this statement or Wolfline Capital’s client due-diligence process may be sent to: [email protected]
This statement is a public summary of Wolfline Capital’s approach and does not replace any internal policy, contractual term or legal obligation applicable to a particular engagement.