Registered filing agents (“RFA”), are required  to comply with the anti-money laundering and counter terrorism financing requirements which are set out as terms and conditions in the ACRA (Filing Agents and Qualified Individuals) Regulations 2015. To ensure this, ACRA has appointed private sector compliance firms (“Reviewer”) to assist ACRA to perform compliance reviews on RFAs. More information about the Reviewers may be found below. 

RFAs that undergo these compliance reviews will benefit from observations made by the Reviewer so as to make improvements to their anti-money laundering and counter terrorism financing practices. RFAs will also receive a compliance assessment report after the completion of the compliance review.

Scope and methodology of compliance review

The compliance review will include the following areas: 

  • general information about the RFA’s business activities, compliance staff strength and appointment of compliance officer, and overall assessment of its money laundering and terrorism financing risks;
  • the approach that the RFA takes in making risk assessments concerning money laundering and terrorism financing issues;
  • the scope of the RFA’s internal policies, procedures and controls;
  • the customer due diligence and enhanced customer due diligence undertaken by the RFA;
  • the obtaining of beneficial ownership information by the RFA;
  • the ability and turnaround time of the RFA to provide beneficial ownership information to ACRA;
  • suspicious transaction reporting;
  • the internal communication of internal policies, procedures and controls by the RFA; and
  • the scope and frequency of training for the RFA’s employees.

ACRA’s follow up action after the compliance review

Arising from the findings that the Reviewer provided to ACRA, ACRA may require the Reviewer to contact the RFA for follow-up compliance reviews.

ACRA may also deploy its own officers to follow-up with the RFA in writing to address some of the findings that the Reviewer has provided to ACRA or conduct an inspection at the RFA’s premises or to interview the RFA or the persons who represented the RFA during the compliance review by the Reviewer.  ACRA also has the legal powers to impose sanctions on the RFA if it is found to have committed breaches of the ACRA Act 2004 and the ACRA (Filing Agents and Qualified Individuals) Regulations 2015.

Name of Appointed Reviewers

  1. Alexis Chin
  2. Carissa Tan
  3. Claire Foo Xin Rui
  4. Clarence Tan
  5. Dawn Chiam
  6. Elaine Zhang
  7. Goi Teck Yam
  8. Grace Zhang
  9. Hannah Nyanavoli
  10. Ian Fang Shengyu
  11. Irving Yeo Jun Hui
  12. Janene Cortes
  13. Jeffery Ho
  14. Jocelyn Teo
  15. Kantha Rupan S/O Arivalagan
  16. Kar Arpita
  17. Katherine Li
  18. Koh Wee Guan
  19. Koh Xuan Kai
  20. Laiu Yan Yee
  21. Lee Zhi Xin
  22. Lek Jing Ting
  23. Melissa Ang Jia Hui
  24. Melissa Lim Seok Tiang (Melissa Lin Shuzhen)
  25. Mithiran Rethnam
  26. Nathan Khoo
  27. Ng Guanneng
  28. Nicholas Koh
  29. Nicole Tay
  30. Ong Andrew
  31. Ong Ee Chow
  32. Ooi Jin Neng
  33. Rohit Thadani
  34. Samantha Hui Ling Low
  35. Samuel Ang
  36. Samuel Francis
  37. Sandra Chow Pei San
  38. Sarah Ow Yong
  39. Serene Teh
  40. Sherlyn Lee Min Hui
  41. Siew Carene
  42. Sim Ying Ying
  43. Sow Zhao Sean
  44. Srisuriya Mohan
  45. Tammie Tan
  46. Tan Ann Chi
  47. Tan Sang Thai
  48. Tan Xuan yun
  49. Tanya Manaw
  50. Toh Wing Yue Mark Michael
  51. Vern Ching
  52. Wang Zheng Rong
  53. Yang Rui
  54. Yeo Kaiting
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