Compliance Review Programme

Compliance Review Programme

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

  1. Agilan Gunasegaran
  2. Anton Ranil Amarasiri
  3. Arivalagan Kantha Rupan
  4. Chan Jun Wei
  5. Chang Ceslie Zhing Fang
  6. Cheung Yuet Ting
  7. Chiam Dawn Yuan Yun
  8. Chng Su Yun
  9. Chow Pei San
  10. Claire Foo Xin Hui
  11. Danaraj Anbalagan
  12. Fang Ian
  13. Fong Hui Wen Wynne
  14. Fu Freya Zijia
  15. Goh Ashley Sio Wui
  16. Ho Marcus Yong Hui
  17. Hon Wen Xin
  18. Khoo Nathan
  19. Koh Mei Ting
  20. Koh Nicholas
  21. Koh Xuan Kai
  22. Kulandhyan Hemadharrshini
  23. Lee Rayna Xin Ying
  24. Lee Wei Hao
  25. Lee Zhi Xin
  26. Lee, Jaelyn Jia Lin
  27. Lek Jing Ting
  28. Lim Alair Li Xian
  29. Lim Dawn
  30. Lim Edna Yi Jieh
  31. Lim Jun Bin
  32. Lim Kah Sim
  33. Lim Siew Kim
  34. Mohan Srisuriya
  35. Muthipalani Myili
  36. Neo Wen Jun
  37. Ng Axel Jia Xue
  38. Ng Jane
  39. Ng Jun Hao
  40. Ng Rhoda Belle
  41. Ng Zhi Jun
  42. Nur Liyana Binti Khairul Shah
  43. Ong Andrew
  44. Shi Wylson Yongsheng
  45. Siew Carene
  46. Sim Shen
  47. Sow Zhao Sean
  48. Tan Chin Lin
  49. Tan Wei Qi
  50. Tay Peng Yong Kelvin
  51. Tian Karsandra Wan Xin
  52. Toh Mark Michael Wing Yue
  53. Toh Tricia
  54. Wong Yee Hern
  55. Yan Steven Li
  56. Yeo Amber
  57. Yip Seow Wei

Safeguarding Registered Dealers’ Information

S/No. Question & Answer
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")
2Qn: 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.
3Qn: 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).
4Qn: 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.
5Qn: 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.
6Qn: Who can I contact from ACD if I have feedback on the CRP?

Ans: You can email ACD at CRP@mlaw.gov.sg.

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