Sets how the company identifies its counterparties and guards against money laundering and terrorist financing.
Scope
This policy applies to every counterparty with which the company enters a contractual or payment relationship, including buyers, suppliers, landowners, agents and advisers.
Know your counterparty
Before a relationship begins, the company obtains and records the counterparty's legal name, registration number, jurisdiction, registered address, ownership structure, and the identity of any beneficial owner holding more than 25 per cent.
Risk assessment
Each counterparty is assessed for risk by jurisdiction, ownership transparency, the nature of the transaction and the payment route. Higher-risk relationships require additional evidence and approval by a director.
Politically exposed persons
Where a counterparty, its owner or its beneficial owner is a politically exposed person, the relationship requires board approval and enhanced ongoing monitoring.
Payments
Funds are received only from and paid only to accounts in the name of the contracting counterparty. Third-party payments and payments to accounts in unrelated jurisdictions are refused unless approved by the board and documented.
Cash
The company does not accept or make payments in cash.
Records
Identification evidence and screening records are retained for at least seven years after the relationship ends.
Reporting
Any suspicion of money laundering is reported to a director immediately and, where required by law, to the relevant financial intelligence unit. The person who raised the suspicion must not alert the counterparty.
Reporting a concern
Concerns about any matter covered by this policy may be raised with any director or by email to compliance@inbox.case.sg. Reports made in good faith attract no adverse consequence.