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Reliance on third parties

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PSN02 permits a firm to rely on a third party to perform the identification, verification and purpose elements of CDD. Three conditions apply. The third party must itself be subject to and supervised for AML/CFT requirements consistent with the FATF standard. The firm must obtain the CDD information immediately and must be able to obtain the underlying documents on request without delay. The firm remains responsible for the outcome.1 Ongoing monitoring may not be outsourced under the reliance provision, though it may be outsourced as a service under the Guidelines on Outsourcing (Chapter VII). The firm must document the assessment of the third party and review it periodically.

Reliance is most relevant in two configurations. The first is intra-group: a Singapore MPI relying on CDD performed by its Zug affiliate on a shared customer. Here the question is whether the Zug affiliate, as a member of a Swiss self-regulatory organisation under the Anti-Money Laundering Act (AMLA, GwG), satisfies the "subject to and supervised" test. In my view it does, since SRO supervision is recognised by the FATF as adequate supervision of Swiss financial intermediaries, but the Singapore firm must document that view and must still screen and monitor on its own account. Chapter VIII develops the point. The second configuration is reliance on an introducing broker or a licensed trust company that brings a client structure. The Singapore firm must not accept the introducer's summary. It must hold the identification data itself and must be able to produce the documents on inspection.

CDD elementStandard (PSN02 para. 6)Simplified (para. 7)Enhanced (para. 8)
Identify and verify customerRequired before relationship or transactionRequired, reduced depthRequired
Beneficial ownerIdentify, reasonable verificationIdentify, may rely on public register for low-risk entitiesIdentify and verify, with structure chart
Purpose and natureRequiredMay be inferred from productDocumented in detail
Source of fundsWhere risk warrantsNot usuallyRequired
Source of wealthNot usuallyNot requiredRequired
Senior management approvalNot requiredNot requiredRequired to open and to continue
Review frequency2–3 years, trigger-basedLonger cycleAnnual and trigger-based
ScreeningOnboarding and periodicOnboarding and periodicOnboarding, periodic, enhanced adverse media

Notes

  1. MAS Notice PSN02, para. 9 (performance of measures by third parties). ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For Hong Kong, our parallel site HongkongIQ.com offers the same practical guidance. For crypto and digital assets, dltreg.com covers legal, tax and fiduciary services. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.