1.1 It is recognised globally that the fight against ML, TF and PF has to be a coordinated global effort if positive results are to be achieved, as ML TF and PF permeate national borders. Singapore recognises the global concern regarding ML, TF and PF, and the ramifications of such activities on the integrity of the Territory's financial system, the stability of its economy, and the safety of its citizens
1.2 Singapore is an active member of the Financial Action Task Force (FATF), the global standard setting and oversight body for AML/CFT/CPF. As co-chair of its Policy Development Group, Singapore collaborates closely with fellow AML/CFT/CPF policy makers and supervisors to develop international standards.
1.3 The Monetary Authority of Singapore (MAS) is Singapore’s central bank and integrated financial regulator. Its focus is regulating and licensing financial institutions, such as banks, crypto-related businesses, and brokers. The MAS also publishes guidelines for other types of financial institutions such as insurance companies.
The MAS is as an autonomous regulatory authority responsible for the regulation, supervision, and inspection of all financial services in and from within Singapore, is responsible for upholding the integrity of Singapore as a well-regulated international finance centre and safeguarding the economic interests of the Territory by:
1.4 Monetary Authority of Singapore Act, 1970, establishes the MAS and gives it the authority to regulate the financial services sector in Singapore, to authorise and supervise entities and persons who conduct financial services business in compliance with relevant Singapore legislation.
1.5 The following regulated activities are considered financial services business:
The Designated Non-Financial Businesses and Professions (DNFBPs) defined under the AML/CFT/CPF regulations of Singapore include:
1.6 The MAS's licensing regime is geared towards protecting market participants by preventing those individuals, who may be inclined on using the Singapore for illicit or criminal purposes, from establishing corporate structures in the Territory and providing services to entities that may wish to operate in or from within the jurisdiction, or using the Territory's financial system to funnel illicit gains or fund illicit operations.
1.7 The MAS is the integrated regulator and supervisor of financial institutions in Singapore. MAS establishes rules for financial institutions which are implemented through legislation, regulations, directions and notices.
It is established under and governed by Monetary Authority of Singapore Act, 1970 from which it derives its powers, in addition to those prescribed in the Corruption, Drug Trafficking, and Other Serious Crimes Act 1992 (CDSA), as amended.
Some other important AML regulations include:
1.8 MAS is not the only financial regulator in Singapore. Facilities such as casinos are overseen by the Casino Regulatory Authority of Singapore. Meanwhile, real estate agencies have to comply with Council for Estate Agencies regulations.
1.9 The MAS has the responsibility for the supervision and monitoring of the Non-Profit Organisations ("NPOs") and the Designated Non-Financial Businesses and Professions ("DNFBPs"), and part of that mandate is to ensure that compliance procedures and obligations with respect to money laundering and terrorist financing are understood and complied with by the NPOs and DNFBPs.
1.10 Sections 43, 44, 46, and 47 of the Corruption, Drug Trafficking, and Other Serious Crimes Act 1992 (CDSA), as amended, cover the prevention of money laundering and its criminalization, make it imperative for persons to make a report of any information that comes to his or her knowledge in the course of any suspicious business activity or transaction in his or her employment.
2.1 It is the policy of Wolfline Capital PTE. LTD to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the financing of terrorist or criminal activities. We will comply with all applicable requirements and regulations. Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Also, Wolfline Capital PTE. LTD is intended to provide all necessary means to strengthen the MAS's supervisory, enforcement and domestic and international cooperation regimes, thereby assisting in preventing money laundering and any activity that facilitates money laundering, the funding of terrorists or other criminal activities in or from within Singapore.
2.2 Having regard to the obligation by the applicable regulations to make it imperative for persons to make a report of any information that comes to his or her knowledge in the course of any suspicious business activity or transaction in his or her employment of financial institutions, non-financial businesses, entities and organisations, Wolfline Capital PTE. LTD deemed it necessary to ensure that reporting of suspicious activities to the MAS or entitled legal officers of the Commercial Affairs Department is of the best and highest quality.
2.3 Our AML/CFT/CPF policies, procedures and internal controls are designed to ensure compliance with all applicable regulations and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.
2.4 The Policy Wolfline Capital PTE. LTD has in place this policy that are designed to assist in the recognition, prevention and reporting of money laundering activities.
3.1 Money laundering is not a single act but is generally defined as "the processing of criminal proceeds to disguise their illegal origin". Essentially, it is engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have originated from legitimate sources or constitute legitimate assets.
3.2 Generally, money laundering occurs in three stages:
3.3 Terrorist financing may be described as the use of funds, or the making available of funds, for the purposes of terrorism; or the acquisition, possession, concealment, conversion or transfer of funds that are, directly or indirectly, intended to be used or made available for the purposes of terrorism. TF may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. A key difference between terrorist financiers and traditional criminal organizations is the legitimate sources of funds used by terrorist financiers. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.
3.4 Proliferation Financing refers to “the act of providing funds or financial services which are used, in whole or in part, for the manufacture, acquisition, possession, development, export, trans-shipment, brokering, transport, transfer, stockpiling or use of nuclear, chemical or biological weapons and their means of delivery and related materials (including both technologies and dual use goods used for non-legitimate purposes), in contravention of national laws or, where applicable, international obligations".
In essence, any act of providing funds or financial services to any person (legal or otherwise) for purposes of financing the production or use of WMD constitutes an act of proliferation; this includes any form of technology or goods that have dual uses if used for purposes that are not legitimate.
Anti-money laundering legislation in Singapore, and indeed worldwide, recognizes the use of professional services for money laundering. The AML (Anti-Money Laundering) and CFT (Combating the Finance of Terrorism) laws in these various jurisdictions have therefore been extended to apply beyond the traditional regulated institutions to include independent legal professionals and trust and company service providers.
Singapore implements the United Nations Security Council Resolutions (“UNSCR”) which prohibit specified transactions, such as the export of luxury goods, with individuals and entities designated as being involved in the proliferation of weapons of mass destruction and its financing. The relevant information and full listings of persons designated by UNSCRs can be found on the UN website.
The main AML regulation in Singapore is the Corruption, Drug Trafficking, and Other Serious Crimes Act 1992 (CDSA). The Act defines the roles of government authorities and imposes rules for money laundering prevention, including reporting procedures and penalties for criminals.
Some other important AML regulations include:
Any references to the Guidelines for Regulated Dealers in the Precious Stones and Precious Metals Dealers Sector on Anti-Money Laundering/Countering the Financing of Terrorism/Countering Proliferation Financing as of 2 May 2024 or Notice to Capital Markets Intermediaries Monetary Authority of Singapore Act 1970 on prevention of money laundering and countering the financing of terrorism – capital markets intermediaries should be construed as references to common understanding on AML/CFT/CPF regulations in Singapore.
The Wolfline Capital PTE. LTD is NOT a regulated dealer, the Wolfline Capital PTE. LTD is not required to obtain a license due to the Wolfline Capital PTE. LTD does not deal in the sphere of precious stones and precious metals.
Relations between Capital Markets Intermediaries (also referred to as the “CMI”) and Monetary Authority of Singapore are regulated by Notice to Capital Markets Intermediaries Monetary Authority of Singapore Act 1970 on prevention of money laundering and countering the financing of terrorism – capital markets intermediaries.
Relations between Capital Markets Intermediaries (also referred to as the “CMI”) and Monetary Authority of Singapore are regulated by Notice to Capital Markets Intermediaries Monetary Authority of Singapore Act 1970 on prevention of money laundering and countering the financing of terrorism – capital markets intermediaries.
(a) the Wolfline Capital PTE. LTD shall exercise due diligence when dealing with customers, natural persons appointed to act on the customer’s behalf, connected parties of the customer and beneficial owners of the customer.
(b) the Wolfline Capital PTE. LTD shall conduct its business in conformity with high ethical standards, and guard against establishing any business relations that are or may be connected with, or facilitates or may facilitate money laundering or terrorism financing.
(c) the Wolfline Capital PTE. LTD shall, to the fullest extent possible, assist and cooperate with the relevant law enforcement authorities in Singapore to prevent money laundering and terrorism financing.
[In accordance with Notice to Capital Markets Intermediaries Monetary Authority of Singapore Act 1970 on prevention of money laundering and countering the financing of terrorism – capital markets intermediaries as amended by MAS Notice SFA04-N02 (Amendment) 2022].
The Regulations create mandatory requirements:
Establishing internal policies and procedures with regard to compliance and AML
Communicating policies to all new employees and explaining any updates to them to existing employees at least on an annual basis
Adequately training staff to identify and tackle suspicious activity and be aware of the consequences of entities violating regulations or not sufficiently monitoring risk
Conducting business risk assessment to identify the overall ML/FT risk the business is exposed to, including the risk factors to be considered
Reporting suspicious transactions to regulatory authorities
In brief the Wolfline Capital PTE. LTD Anti-Money Laundering Statement's key principles are:
Protect Wolfline Capital PTE. LTD from money laundering & terrorist financing.
Maintain a written set of AML policy and procedures, a system of internal controls to ensure ongoing AML compliance and to take appropriate action, once suspicious activity is detected, through the reporting of such transactions in line with the guidelines set out by the Monetary Authority of Singapore.
Comply with applicable anti-money laundering & terrorist financing laws and regulations as established by the Monetary Authority of Singapore and subsidiary regulators.
Report all identified suspicious activities to the extent that Wolfline Capital PTE. LTD can do so under all applicable foreign and domestic laws.
Retaining the entire customer related documents for a period specified as per the Monetary Authority of Singapore.
Cooperate fully with law enforcement and regulatory agencies to the extent that it can do so under all applicable laws.
We will monitor customer’s activity for unusual requests, taking into account risk factors and red flags that are appropriate to our business. (Red flags are partially identified in the Section b. of the “Guidelines”, and also in additional AML/CFT/CPF regulations specified for each exact field as specified in the “Singaporean Legislation”). The director or his or her designee will be responsible for this monitoring, will review any activity that our monitoring system detects, will determine whether any additional steps are required, will document when and how this monitoring is carried out, and will report suspicious activities to the appropriate authorities. The director or his or her designee will conduct an appropriate investigation and review relevant information from internal or third-party sources before the authorities are notified.
a) We will file a report with the Suspicious Transaction Reporting Office (STRO) or MAS, or the appropriate regulatory authority for any transactions where we know, suspect or have reason to suspect:
(1) the transaction involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity as part of a plan to violate or evade law or regulation or to avoid any transaction reporting requirement under law or regulation;
(2) the transaction is designed, whether through structuring or otherwise, to evade any requirements of the regulations;
(3) the transaction has no business or apparent lawful purpose or is not the sort in which the customer would normally be expected to engage, and after examining the background, possible purpose of the transaction and other facts, we know of no reasonable explanation for the transaction; or
(4) the transaction involves the use of Wolfline Capital PTE. LTD to facilitate criminal activity.
We will also file a report and notify the appropriate law enforcement authority in situations involving violations that require immediate attention, such as terrorist financing or ongoing money laundering schemes. We may file a voluntary report for any suspicious transaction that we believe is relevant to the possible violation of any law or regulation but that is not required to be reported by us. It is our policy that all suspicious activities will be reported regularly to the Board of Directors and appropriate senior management.
We have developed ongoing employee training under the leadership of the director and senior management. Our training will occur on at least an annual basis. It will be based on our firm's size, its customer base, and its resources and be updated as necessary to reflect any new developments in the law. Our training will include, at a minimum:
(1) how to identify red flags and signs of money laundering and/or the financing of terrorism that arise during the course of the employees' duties;
(2) what to do once the risk is identified (including how, when and to whom to escalate unusual customer activity or other red flags for analysis and, where appropriate, the filing of reports to the authorities;
(3) what employees' roles are in Wolfline Capital PTE. LTD compliance efforts and how to perform them; and
(4) the disciplinary consequences (including civil and criminal penalties) for non-compliance with the AML/CFT/CPF regulations. We will develop training in our firm, or contract for it. Delivery of the training may include educational pamphlets, videos, intranet systems, in-person lectures and explanatory memos. We will maintain records to show the persons trained, the dates of training and the subject matter of their training. We will review our operations to see if certain employees, such as those in compliance, margin and corporate security, require specialized additional training. Our written procedures will be updated to reflect any such changes.
Employees will promptly report any potential violations of Wolfline Capital PTE. LTD AML/CFT/CPF compliance program to the director, unless the violations implicate the director, in which case the employee shall report to the relevant authorities. Such reports will be confidential, and the employee will suffer no retaliation for making them.
Wolfline Capital PTE. LTD has reviewed all areas of its business to identify potential money laundering and/or financing of terrorism risks that may not be covered in the procedures described above. The major additional areas of risk include future changes to regulations and hacking attempts on Wolfline Capital PTE. LTD servers. Additional procedures to address these major risks are maintaining constant contact with the MAS and performing daily security checks on Wolfline Capital PTE. LTD server security procedures, performed by a dedicated server security specialist.a
Wolfline Capital PTE. LTD is committed to complying with the sanctions laws and regulations of the United Nations (UN), the European Union (EU) and the United States (US), as well as all applicable sanctions laws and regulations in the jurisdictions in which we operate.
Wolfline Capital PTE. LTD has a Measures in relation to Sanctions Policy that defines the minimum standards in which Wolfline Capital PTE. LTD and its subsidiaries must comply with to meet the above obligations.
This includes:
In order for us to ensure compliance with any sanctions programme, customers may be required to furnish Wolfline Capital PTE. LTD with additional information as and when necessary.
The Wolfline Capital PTE. LTD must take additional measures relating to targeted financial sanctions. This means that before entering into a transaction, the Wolfline Capital PTE. LTD is required to assess whether the customer, or any person on whose behalf the customer is acting, or a beneficial owner of the customer (where the customer is an entity or legal arrangement) is:
If they are found in the terrorist designations and financial sanctions lists (refer to paragraph 6.4.3 of the Guidelines), the Wolfline Capital PTE. LTD should ensure that it does not deal with them. If the Wolfline Capital PTE. LTD has reason to suspect that the customer may be a terrorist, terrorist entity or designated person, the Wolfline Capital PTE. LTD must:
Wolfline Capital PTE. LTD obliges to assess whether the customer, or any person on whose behalf the customer is acting, or a beneficial owner of the customer (where the customer is an entity or legal arrangement) is any above-mentioned individuals or such individual or legal entity has connections with such individuals, a list on which is provided.
We may also be required to take appropriate measures should the business relationships result in a risk to Wolfline Capital PTE. LTD.
For further AML inquiries please contact us at [email protected]