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. Amber Yeo
  2. Andrew Ong
  3. Carene Siew
  4. Chan, Jun Wei
  5. Chang, Ceslie Zhing Fang
  6. Cheung, Yuet Ting
  7. Chng, Su Yun
  8. Claire Foo Xin Hui
  9. Dawn Lim
  10. Fu, Freya Zijia
  11. Goh, Ashley Sio Wui
  12. Ho, Marcus Yong Hui
  13. Ian Fang
  14. Jolvin Goh
  15. Kantha Rupan S/O Arivalagan
  16. Khoo, Nathan
  17. Koh Xuan Kai
  18. Koh, Mei Ting
  19. Kulandhyan, Hemadharrshini
  20. Lee, Rayna Xin Ying
  21. Lee, Wei Hao
  22. Lim, Alair Li Xian
  23. Lim, Edna Yi Jieh
  24. Muthipalani, Myili
  25. Neo, Wen Jun
  26. Ng Gui Rui
  27. Ng, Axel Jia Xue
  28. Ng, Jane
  29. Nicholas Koh
  30. Quek, Stephanie En Yi
  31. Shi, Wylson Yongsheng
  32. Sow, Zhao Sean
  33. Srivalsan, Krishna
  34. Tan Chin Lin
  35. Tan, Wan Xuan
  36. Tee, Shamus Ren Jie
  37. Tian, Karsandra Wan Xin
  38. Vanessa Choi
  39. Wong, Lai Yee
  40. Yan, Steven Li

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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