FORM B – Risk Determination and Screening Checklist
EAs and RESs must conduct screening and risk assessment for all persons involved in rental, sale, and purchase transactions as part of Customer Due Diligence. This includes clients, BOs, and persons the client represents. A separate form must be completed for each person.
Person being screened
Section 1: Check for PEPs and Lists on Terrorist Designation and Designated Individuals and Entities
1. Is the client or BO a foreign PEP, a family member or close associate of a foreign PEP?
2. Is the transaction high risk? (Refer to red flag indicators in Annex A)
3. Is the client or BO from a High-Risk or Other Monitored Jurisdiction?
4. Is the client or BO a designated individual or entity under the Terrorism (Suppression of Financing) Act 2002 (TSOFA)? Any match?
If the screening result is positive, proceed to Q6 below.
5. Is the client or BO a designated individual or entity under United Nations sanctions lists / regulations under the United Nations Act 2001 (UN Act)? Any match?
6. Has the client or BO obtained an exemption order under the TSOFA or UN Act?
If screening result for either Q4 or Q5 is positive and no exemption order has been obtained under TSOFA or UN Act, EAs and RESs must not carry out any transaction with the client and must terminate any transaction already entered into. They must submit an STR via SONAR.
Section 2: Red Flag Indicators Checklist
Important Note: EA/RES must determine whether to file an STR if the answer
to any of the above is a “Yes”.
Section 3: RES’s Risk Determination and Conclusions
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