Overview
Regulated dealers are required to comply with the Precious Stones and Precious Metals (Prevention of Money Laundering and Terrorism Financing) Act 2019 (“PSPM Act”) and Precious Stones and Precious Metals (Prevention of Money Laundering and Terrorism Financing) Regulations 2020 (“PMLTF Regulations”), and adhere to the Guidelines for Regulated Dealers in the Precious Stones and Precious Metals Dealers (“PSMD”) sector on anti-money laundering/countering the financing of terrorism (“AML/CFT”).
Under the Compliance Review Programme (“CRP”), the Ministry of Law has appointed a professional services firm, Deloitte & Touche LLP (“Reviewer”), to perform compliance reviews on registered dealers.
The Reviewer will assess the registered dealers’ level of compliance with the PSPM Act and PMLTF Regulations and provide guidance, where necessary. The reviews will be conducted through a combination of correspondence via emails, phone calls and meetings. Registered dealers will receive a report highlighting non-compliances, areas for improvement and required remedial and corrective actions (if any).
Information of Reviewers
- Agilan Gunasegaran
- Anton Ranil Amarasiri
- Arivalagan Kantha Rupan
- Chan Jun Wei
- Chang Ceslie Zhing Fang
- Cheung Yuet Ting
- Chiam Dawn Yuan Yun
- Chng Su Yun
- Chow Pei San
- Claire Foo Xin Hui
- Danaraj Anbalagan
- Fang Ian
- Fong Hui Wen Wynne
- Fu Freya Zijia
- Goh Ashley Sio Wui
- Ho Marcus Yong Hui
- Hon Wen Xin
- Khoo Nathan
- Koh Mei Ting
- Koh Nicholas
- Koh Xuan Kai
- Kulandhyan Hemadharrshini
- Lee Rayna Xin Ying
- Lee Wei Hao
- Lee Zhi Xin
- Lee, Jaelyn Jia Lin
- Lek Jing Ting
- Lim Alair Li Xian
- Lim Dawn
- Lim Edna Yi Jieh
- Lim Jun Bin
- Lim Kah Sim
- Lim Siew Kim
- Mohan Srisuriya
- Muthipalani Myili
- Neo Wen Jun
- Ng Axel Jia Xue
- Ng Jane
- Ng Jun Hao
- Ng Rhoda Belle
- Ng Zhi Jun
- Nur Liyana Binti Khairul Shah
- Ong Andrew
- Shi Wylson Yongsheng
- Siew Carene
- Sim Shen
- Sow Zhao Sean
- Tan Chin Lin
- Tan Wei Qi
- Tay Peng Yong Kelvin
- Tian Karsandra Wan Xin
- Toh Mark Michael Wing Yue
- Toh Tricia
- Wong Yee Hern
- Yan Steven Li
- Yeo Amber
- Yip Seow Wei
S/No. |
Question & Answer |
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1 |
Qn: What information will Deloitte & Touche LLP (“Deloitte”) request?
Ans: Deloitte will request for the following information from registered dealers:
a. Organisational structure, reporting lines, headcount, roles and responsibilities of the various parties
b. Details of offices and outlets, including address and headcount at each outlet
c. Target customers
d. Product listing (comprising precious stones, precious metals and precious products, and values). Registered dealers will need to denote the top 10 highest value products.
e.Transaction records for sales and purchases of precious stones, precious metals and precious products (e.g. sales and purchases invoices/cash receipts/cash register/cash books)
f. Audited financial statements. If not available, latest monthly financial statements or those filed with Accounting and Corporate Regulatory Authority ("ACRA") |
2 | Qn: What will the requested information be used for?
Ans: The information will be used by Deloitte to assess the registered dealers’ level of compliance with the requirements of the Precious Stones and Precious Metals (Prevention of Money Laundering and Terrorism Financing) Act 2019 (“PSPM Act”) and Precious Stones and Precious Metals (Prevention of Money Laundering and Terrorism Financing) Regulations 2020 (“PMLTF Regulations”). This is in addition to the cash transaction reports which regulated dealers are required to submit.
For Deloitte to perform this assessment, the Anti-Money Laundering/Countering the Financing of Terrorism Division (“ACD”) has set out a list of information which Deloitte will need for the review. Deloitte is also expected to substantiate any potential contraventions of the PSPM Act and PMLTF Regulations with supporting documents in their report to ACD. ACD will follow through on instances of non-compliance uncovered by Deloitte. |
3 | Qn: How do I submit the requested information to Deloitte?
Ans: Registered dealers should submit all requested information in soft copies. Where the original documents are in Microsoft Excel format, please submit the Excel file. Please note that the information should be sent via email in a password protected or AES 256-encrypted (preferred) attachment, whichever is available. The corresponding password of minimum 12 characters in length or encryption key should be delivered via a separate transmission channel (e.g. telephone). |
4 | Qn: How will the information be safeguarded?
Ans: Deloitte and its appointed reviewers are required to comply with the Government’s requirements on information security and the Official Secrets Act. All the appointed Deloitte reviewers have been screened and have also declared that they do not have any conflict of interest. Deloitte also has to destroy the information collected from the registered dealers after the completion of the CRP reviews. |
5 | Qn: Who can I contact from Deloitte if I have questions on the CRP?
Ans: You can email Deloitte at sgadvisorypsmdcrp@deloitte.com. You can also contact them at 6800 3913/6800 4544. |
6 | Qn: Who can I contact from ACD if I have feedback on the CRP?
Ans: You can email ACD at CRP@mlaw.gov.sg. |