Anti-Money Laundering/Countering the Financing of Terrorism for Fund Management Companies

When must Customer Due Diligence (CDD) be conducted for fund management companies?

According to MAS (Guidelines),
last revised 24 April 2015 

When CDD is to be Performed and Linked Transactions

6-2-1 Paragraph 6.4 of the Notice (CDD) is applicable to a CMI when it undertakes transactions for customers who or which have not established business relations with the CMI.

6-2-2 A CMI should monitor whether the related or linked transactions exceed the thresholds set out in paragraph 6.3(b) of the Notice and should take these into consideration when formulating scenarios and parameters.

6-2-3 Two or more transactions may be related or linked if they involve the same sender or recipient. A CMI should be aware that transactions may be entered into consecutively to deliberately restructure an otherwise single transaction, with the intention of circumventing applicable thresholds set out in the Notice in relation to the circumstances set out in paragraph 6.3(b).