While screening your prospective client one day, you found out that he is featured in a news report on possible involvement in criminal activities and that law enforcement authorities are conducting an investigation on him. What should you do? Or when your client appears hesitant or declines to put his name on any document that would connect him with the goods he intends to store in your warehouse, should you keep quiet about it and continue the business transaction?
Both scenarios above are among the common indicators of suspicious transactions with possible links to money laundering or terrorism financing activities. You should consider lodging a Suspicious Transaction Report (STR) in writing, addressed to Head, Suspicious Transaction Reporting Office (STRO) of the Commercial Affairs Department (CAD), or via email to STRO@spf.gov.sg.
WHY SHOULD I DISCLOSE MY SUSPICION TO THE SUSPICIOUS TRANSACTION REPORTING OFFICE?
Under Singapore's laws, all persons are legally obliged to lodge an STR if they know or have reason to suspect, in the course of his business or employment, that any transaction or the related property is connected to drug dealing or criminal conduct. All persons are also required to make a police report if they have information or possess any property pertaining to terrorism financing or terrorist activities. Any person, including traders and declaring agents, who contravenes these legal provisions, shall be guilty of a criminal offence.
WHAT SHOULD I DO TO PROTECT MY BUSINESS FROM BEING INADVERTENTLY USED AS A CONDUIT FOR MONEY LAUNDERING AND TERRORISM FINANCING?
You should adopt robust internal procedures to protect the integrity of your business. Some suggested preventive measures that you are strongly encouraged to consider are:
More examples of common indicators of suspicious transactions can be found in Circular No. 15/2014 which Singapore Customs issued in
collaboration with the CAD.