EP 200 Anti-Money Laundering and Countering the Financing of Terrorism - Requirements and Guidelines for Professional Accountants in Singapore

Expectations of professional accountants to combat money laundering and terrorist financing are rising. Internationally, there are increasing calls for professional accountants to adopt measures that are at least up to the international standards recommended by the Financial Action Task Force (FATF). Singapore is a member of the FATF, an inter-governmental body established to set standards and to promote effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction, and other related threats to the integrity of the international financial system. As a member of the FATF, Singapore is obliged to comply with the "International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation" issued by the FATF (FATF Recommendations) and is subject to FATF mutual evaluations on the adoption of FATF Recommendations. The FATF Recommendations include requirements for accountants.

In response, ISCA has developed the new EP200. This project demonstrates the commitment of ISCA to play its part in helping Singapore as a FATF member to combat money laundering and terrorist financing on a global scale.

EP 200 is applicable to all professional accountants and professional firms¹ in Singapore.

All ISCA Members are required to comply with the requirements in EP 200. Apparent failure to do so may result in an investigation into the member’s conduct by the Investigation Committee of ISCA. EP 200 (Revised on 1 June 2023) adopts the anti-money laundering and countering the financing of terrorism (AML/CFT) requirements which are included in the Accountants (Prevention of Money Laundering and Financing of Terrorism) Rules 2023. (please click here for the press release).

¹ A professional firm is an accounting corporation, an accounting firm or an accounting LLP approved under the Accountants Act; or an entity owned or controlled by a professional accountant or professional accountants, that provide professional services. Professional services are services requiring accountancy or related skills performed by a professional accountant including accounting, auditing, taxation, management consulting and financial management services, as well as the following designated high risk services:

(a)          Buying and selling of real estate;
(b)          Managing of client money, securities or other assets;
(c)          Management of bank, savings or securities accounts;
(d)          Organisation of contributions for the creation, operation or management of companies; and
(e)          Creation, operation or management of legal persons or arrangements, and buying and selling of business entities. 

Notes:

1.    EP 200 (Revised on 25 November 2015) 

Minor amendments were made to EP 200 on 25 November 2015 to change references from the Monetary Authority of Singapore (MAS) Regulations to the United Nations Regulations for the purpose of ensuring technical accuracy.

2.    EP 200 (Revised on 10 August 2016)

The Singapore Police Force (SPF) has recently revamped their website in order to integrate their different websites. Due to this integration, the Commercial Affairs Department’s (CAD’s) Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) website has been moved to the integrated website.

As EP 200 makes reference to the previous website, page 10 of EP 200 has been updated on 10 August 2016 accordingly to reflect updates.

3.    EP 200 (Revised on 28 March 2017)

EP 200 provides the anti-money laundering (AML) and countering the financing of terrorism (CFT) requirements and guidelines for professional accountants in Singapore. EP 200 is also adopted by ACRA and is applicable to public accountants and accounting entities registered under the Accountants Act who are regulated by ACRA.

Arising from the FATF Mutual Evaluation Report of Singapore, ISCA has made amendments to EP 200 on 28 March 2017 to address the findings as well as other amendments to provide clarity to existing requirements and guidelines. The key amendments include:   

• Making the existing Supplement A of EP 200 mandatory for auditors;                       
• With respect to trusts, to identify the settlor, the trustee(s), the protector, each beneficiary or class of beneficiaries (including ultimate beneficiaries), and any other natural person exercising ultimate effective control over the trust;  
• Removing the current exemption for identification and verification of beneficial owners for government entities; 
• With respect to certain designated accountants who act as trustees, to disclose their status to identified financial institutions and designated non-financial businesses and professions when forming a business relationship; and  
• Extending screening requirements to cover the beneficial owners of the client, natural persons appointed to act on behalf of the client and connected parties of the client.

The revised EP 200 was effective 1 June 2017. 

4.    EP 200 (Revised on 1 June 2023)

This EP 200 is revised to adopt the AML/CFT requirements which are included in the Accountants (Prevention of Money Laundering and Financing of Terrorism) Rules 2023. These requirements are applicable to professional accountants in public practice and professional firms preparing for or carrying out transactions which are considered high risk.

Professional accountants in public practice and professional firms preparing for or carrying out transactions which are considered high risk are to adopt ACRA’s AML/CFT requirements in entirety.

The AML/CFT requirements remain the same for (i) professional accountants in business, and (ii) professional accountants in public practice and professional firms preparing for or carrying out transactions other than those high risk activities as mentioned above.

EP 200 (Revised on 1 June 2023) is effective 1 July 2023.