Illustrative Customer Due Diligence Templates Page 18
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25EP 200 IG 2
Risk Assessment Questionnaire
Section 1: Client background
Question
Response
6
Yes
No
Client or beneficial owners
or directors is a Politically Exposed Person
(PEP).
Client or beneficial owner or directors is matched with a person in the MAS
Yes
No
control list.
The issues are related to predicate crimes for money laundering and/or fraud
Yes
No
and/or crime (including suspected cases).
Yes
No
Client or beneficial owner or connected party has adverse news based on
searches from Factiva and/or Google.
Yes
No
The issues are related to predicate crimes for money laundering and/or fraud
and/or crime (including suspected cases).
7
Client is involved in High-Risk Industry
.
Yes
No
Yes
No
Client has nominee shareholder/s in the ownership chain where there is no
legitimate rationale.
Yes
No
The nominee shareholder/s represent/s majority ownership
Client is:
Yes
No
-
a shell company or has complex shareholding structure (e.g.,
involving 3 layers or more of ownership structure, different
jurisdictions, trusts); AND
-
without an obvious commercial purpose.
Yes
No
Client is a charitable or non-profit organization that is NOT registered in
Singapore (charities.gov.sg/charity/index.do).
Section 2: Client Location
Please consider as applicable: Client nationality; Place of formation/incorporation; Residential address;
Permanent address; Place of operation; Place where business is established.
Question
Response
Client or beneficial owner or beneficiary is connected to high risk
Yes
No
8
jurisdictions
in any of the above listed aspects.
Client or beneficial owner or beneficiary is connected to a jurisdiction not in a
Yes
No
9
low risk country
.
6
A beneficial owner refers to the natural person who ultimately owns or controls a client and/or the natural person on whose behalf
a transaction is being conducted. It also includes those persons who exercise ultimate effective control over a legal person or
arrangement.
7
As determined by the firm, such as with reference to publications and guidance issued from time to time by the FATF.
8
Refer to the FATF list of high-risk and non-cooperative jurisdictions to determine which countries are high-risk jurisdictions:
9
Determining whether a country is low-risk should be based on the firm’s internal policy and your professional judgment. Reference
should be made to the FATF list of high-risk countries as well.
18
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