Guideline of measures of client due diligence

In accordance with ACRA’s regulations, Healy Consultants implements stringent due diligence checks on all our Clients, to make sure that our business setup and other corporate services do not facilitate money laundering, financing of terrorism and other illegal activities prohibited by Singapore and foreign Governments.

Please read this page for an overview of due diligence procedures to be implemented by all Healy Consultants’ employees. Our Chairman, Aidan Healy, our Compliance department and your department heads are always there to answer your queries.

Why do we implement due diligence checks

  1. Because this is the law – All corporate services providers must implement risk-based assessments of their Clients;
  2. Because this protects Healy Consultants and its employees – If we assist a Client to form a company or open a bank account thereafter used for illegal purposes, we can be punished with fines and prison time by the Singapore Government and we as a socially responsible Firm refuse to facilitate or assist criminal activities;
  3. Because this protects the interest of Healy Consultants’ Clients – Our Clients are honest, law abiding business people and entrepreneurs who do not want to be associated with criminals and Firms assisting criminals.

How do we implement due diligence checks

  1. When you expect to close a sale, always refer to the client risk assessment section for an assessment calculator to help you to determine the risk level of your potential Clients. If the result does not make sense to you, indicate it to Aidan Healy, Compliance Department or your department head;
  2. Validate your risk assessment level with Compliance department, your department manager and Aidan Healy. If the three of them disagree, Compliance department’s assessment always prevails;
  3. Choose the correct due diligence checklist for each Client according to i) his/her risk level and ii) the type of risk(s) our Firm expects to face;
  4. Approval for the content of the checklist must be approved by i) Compliance department, ii) your department head and Compliance for medium risk Client iii) the same + Aidan for high risk Clients;
  5. Obtaining of client due diligence documents is crucial to the commencement of the engagement, hence as a CRO it is your duty to send daily or weekly reminders to obtain all outstanding documents. Note: without the notarized passport/corporate information and preliminary approval from Compliance you are unable to commence engagement or invoice the client. The priority is to obtain the documents required by Compliance for client clearance before seeking those documents required for bank opening (although in most cases the documents would overlap);
  6. If a Client declines to provide the requisite documents, request the client’s reasons for their reservation for providing this information. To note: that many nationalities are sensitive to request for such information for GDPR reasons and for cultural reasons and not necessarily due to suspicious reasons. CROs are expected to be sensitive in the manner they request such information and where the client seems difficult, seek assistance from the Compliance department or ask a Compliance officer to join you in a conversation with the client to assist with explaining the need for these documents and allaying any concerns the client may have;
  7. If the Client continues to refuse to provide due diligence documents, Compliance department will write to the client requesting the same, and if upon request from the Compliance department, client refuses to cooperate, management will unilaterally terminate the engagement. Where fees have been paid by the client, there will be no refund for the Client and no penalty for the CRO;

Before 14 calendars of commencing the engagement, the CRO is to collect 100% of the due diligence documents from the client.

Clients risk assessment and checklists

Risk Assessment Calculator for New Clients

Risk Assessment Calculator for Renewal Clients

Due diligence checklists

Other due diligence measures in place

  1. Compliance will copy the supervisor of the CRO in their email exchange with the CRO where there is delay in obtaining the required due diligence checklist;
  2. Every Thursday, Compliance will also email Aidan Healy and all CEOs Compliance Department’s progress report which will capture the progress with client and supplier files.

Training plan

  1. Every six months, the company organizes a seminar including i) a reminder of due diligence policies in place ii) discussion of problems encountered by staff and solutions to make the due diligence process smoother for everyone and iii) Q&A with staff.
  2. For the Malaysia and Dubai (inclusive of Slovakia) offices a yearly seminar will be conducted.
  3. On a yearly basis, there will be a test conducted to assess the levels of understanding among all CROs and accounting/renewal staff.
  4. There will be penalties imposed on staff who do not pass the compliance test in the first sitting as explained in the table below:

Applicable Penalties for an Officer Not Passing the Annual AML/CFT Test

Tests not clearedCROsAll other officers - Compliance/ Finance/ Accounts/ Renewal Team
1st Round
  • to explain what is it that the officer does not understand;
  • to request assistance from Compliance department to help explain the processes again;
  • no sales/other bonus will be paid until officer passes the test.
  • to explain what is it that the officer does not understand;
  • to request assistance from Compliance department to help explain the processes again;
  • no form of bonus will be paid until officer passes the test.
2nd Round

In an email to be copied to Aidan and relevant CEOs:

  • the officer’s supervisor to provide written explanation for why the officer continues to fail the test; and
  • steps the supervisor intents to take to ensure officer obtains AML/CFT knowledge and pass next test;
  • no sales/other bonus will be paid until officer passes the test.

In an email to be copied to Aidan and relevant CEOs:

  • the officer’s supervisor to provide written explanation for why the officer continues to fail the test; and
  • steps the supervisor intents to take to ensure officer obtains AML/CFT knowledge and pass next test;
  • no form of bonus will be paid until officer passes the test.
3rd Round
  • warning letter to be issued to officer;
  • steps the supervisor intents to take to ensure officer obtains AML/CFT knowledge and pass next test;
  • no sales/other bonus will be paid until officer passes the test.
  • warning letter to be issued to officer;
  • steps the supervisor intents to take to ensure officer obtains AML/CFT knowledge and pass next test;
  • no form of bonus will be paid until officer passes the test.
4th Round
  • warning letter to be issued to officer;
  • supervisor to receive a negative remark in appraisal for inability to improve supervisee’s performance;
  • no sales/other bonus will be paid until officer passes the test.
  • warning letter to be issued to officer;
  • supervisor to receive a negative remark in appraisal for inability to improve supervisee’s performance;
  • no form of bonus will be paid until officer passes the test.
5th Round
  • officer’s service will be terminated;
  • no sales/other bonus will be paid (including whatever amounts that maybe outstanding or to be claimed).
  • officer’s service will be terminated;
  • no form of bonus will be paid (including whatever amounts that maybe outstanding or to be claimed).

Applicable Penalties for lack of compliance with AML/CFT policies and requirements

  • Applicable Penalties for lack of compliance with AML/CFT policies and requirements
    • Gentle reminder from the compliance department or management;
    • Face to face meeting with management to i) explain why the employee fails to implement due diligence checks and ii) find solutions together;
    • Employee warning in writing.
  • If three employee warnings are received for not implementing due diligence policies, Healy Consultants will conduct a meeting with the employee, Aidan Healy, HR and the department head can decide to terminate the employee’s employment for gross misconduct, in accordance with the employment contract of the employee;