Source of Funds & AML Compliance

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Singapore’s reputation as a premier international financial center is grounded in its robust anti-money laundering (AML) regime, strict regulatory standards, and proactive international cooperation. For Global Investor Programme (GIP) applicants, demonstrating the lawful origin and verifiable trail of funds is a central requirement, and failure to comply can lead to delays, rejection, or investigation.

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KYC/AML Documentation Requirements

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All applicants must submit a comprehensive Source of Wealth (SOW) and Source of Funds (SOF) report, supported by verifiable documents. Required documents typically include:

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• Bank reference letters from institutions with established KYC frameworks.
  
• 12–24 months of bank statements showing fund accrual and transfer pathway.
  
• Audited financials of owned companies or businesses, especially for Option A applicants.
  
• Tax returns and income statements to validate declared income and assets.
  
• Sale contracts for any real estate, securities, or businesses liquidated to raise capital.
  
• Certified translations and apostilles for all non-English documents.

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Applicants should expect to be interviewed or questioned on their financial background, particularly if their portfolio is complex or spread across multiple jurisdictions.

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High-Risk Profiles

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The Monetary Authority of Singapore (MAS), in collaboration with the EDB and Ministry of Home Affairs, categorizes some applicants as high-risk due to factors such as:

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• Being a Politically Exposed Person (PEP) or having close associates who are.
  
• Nationality or residence in jurisdictions listed by the FATF as high-risk or non-cooperative.
  
• Source of wealth derived from crypto holdings, art, or non-traditional assets.
  
• Complex offshore holding structures or undocumented trust relationships.
  
  

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In such cases, enhanced due diligence (EDD) is mandatory. This includes forensic background checks, third-party verification of assets, and cross-border financial record reviews.

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Fund Transfer Protocols

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Fund transfers must meet stringent regulatory conditions:

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• Originating account must be in the name of the applicant or a clearly disclosed and approved legal entity.
  
• The receiving bank in Singapore must be licensed by MAS, and will independently review the transaction.
  
• Transfers via money service businesses, cash, or crypto rails are strictly prohibited.
  
• Layered transactions involving shell companies or nominee accounts are red flags.
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Advisors should pre-vet all documentation and consider hiring external compliance firms to prepare an SOW report prior to submission.

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