A Filing Agent (“FA”) is an entity who carries out on behalf of any other person/entity any transaction with The Accounting and Corporate Regulatory Authority (ACRA). ACRA, is the national regulator of business entities, public accountants, and corporate service providers in Singapore. FA may use the electronic transaction system or any other means permitted or directed by ACRA if the electronic transaction system is unavailable.

As a registered filing agent (“RFA”), Sino Secretary complies with the Anti-Money Laundering/Counter Financing of Terrorism (AML/CFT) requirements which are set out as terms and conditions in the ACRA (Filing Agents and Qualified Individuals) Regulations 2015. Moreover, as prescribed by the ACRA regulations, our company also participates in mandatory training programmes, which comprises a prescribed AML/CFT course. The programme aims to ensure that RFAs are well-equipped to comply with AML/CFT regulations through continuous education.

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Customer Due Diligence (CDD) measures are intended to collect and evaluate relevant information about a customer or potential customer. CDD is essential to ensure that the clients remain compliant with the regulations and laws of the regions or markets they are operating in. Depending on specific circumstances, RFAs may also need to conduct additional measures (referred to as enhanced customer due diligence).
The main purposes of Customer Due Diligence (CDD) measures are:
  • To know the customer and understand the customer’s business more insightfully;
  • To protect company’s staff from committing offences under the anti-money laundering and combating the financing of terrorism (Anti-Money Laundering/ Terrorist Financing Compliance) legislation;
  • To comply with obligations under the Anti-Money Laundering/Terrorist Financing Compliance legislation; and
  • To minimise risks of being inadvertently exploited by criminals in their money laundering and financing of terrorism schemes.
  1. Customer Due Diligence (including simplified and enhanced)
Governed by the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), the business relationship between RFAs and their customers has to be continuously monitored. This procedure includes regular review of ownership structures, monitoring transactions of the customers and identifying transactions that are complex, large and unusual. Under certain circumstances (such as customers not being physically present for identification purposes and other high-risk situations), the AMLO would warrant enhanced due diligence requirements and impose additional measures.
2. Ongoing monitoring
Singapore has established a strict and rigorous anti-money laundering (AML) and countering the financing of terrorism (CFT) regime through its comprehensive and sound legal, institutional, policy and supervisory frameworks to ensure that Singapore is not a place for money launderers and terrorist financiers. The relevant legislations in Singapore make it mandatory for a person to present a suspicious transaction report to the Suspicious Transaction Reporting Office, Commercial Affairs Department (CAD) of the Singapore Police Force (STRO) if one has reasonable grounds to suspect transactions related to money laundering or terrorist financing.
3. Making of suspicious transaction reports
As a registered FA, we keep the records of all customer due diligence information (including screening results and risk assessment), and the supporting records. These records must be kept throughout the duration of a business relationship and for an additional period of at least 5 years beginning on the date on which a business relationship ends.
4. Record-keeping
Sino Secretary documents risk assessments of the customers, and the reasons why the due diligence was conducted. It is crucial for us to understand the ML/TF/PF risks associated with the customers/clients.
5. Risk assessment and management
We have implemented and maintained an independent audit function, and we are able to regularly assess the effectiveness of these internal policies, procedures and controls and its compliance with the Regulations.
6. Audit of the internal policies, procedures and controls
We have implemented and maintained an independent audit function, and we are able to regularly assess the effectiveness of these internal policies, procedures and controls and its compliance with the Regulations.
7. Monitoring and management of compliance with, and the internal communication of the internal policies, procedures and controls
Our employees are regularly trained to prevent any money laundering and financing of terrorism and proliferation and comply with other ongoing obligations as an RFA. Also, our employees are aware of any new and emerging techniques, methods and trends in Money laundering/Terrorist financing to the extent that such information is needed to carry out their respective roles with respect to AML/CTF.

As an RFA, Sino Secretary Limited, meets all the requirements of the Accounting and Corporate Regulatory Authority (ACRA) of Singapore.
8. Hiring and training of employees
As RFA, Sino Secretary is required to establish and maintain detailed, up-to-date and risk sensitive internal policies, procedures and controls (IPPC) concerning all of the following matters:
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