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The Company conducts enhanced regular review to ensure Client CDD Information is up to date. For high-value account that has balances of more than USD100,000 or equivalent; the Company will conduct special monitoring by means of phone calls to registered phone number. Existing clients sometimes become PEPs after they enter a business relationship, so it is essential that The Company monitors non-PEP accounts for a change in the PEP status, customer profile or account activity and update customer information. Such ongoing monitoring should be based on risk, consistent with FATF Recommendation 10.
Ongoing Employee Training
The Company ensure a robust internal control policies with ongoing employee training programs. These training programs need to address effective ways of determining whether clients are PEP and to understand, assess and handle the potential risks associated with PEPs. Training should also use real life case studies and examples to ensure it is up to date. Human input and analysis from experienced and trained employees can be more valuable than automated software programs for detecting and handling the risks associated with PEPs. This is especially the case for high net worth customers that are PEPs, which potentially carry the highest corruption and money-laundering risks.
Escalation to senior management
The Company establishes escalation to senior management to engage with high-risk PEPs. Domestic PEPs and foreign PEPs (of account balances more than USD 100,000 or equivalent) are always considered high risk and require the application of enhanced due diligence measures. This should further lead to more proactive steps, in particular, to an increase in the monitoring of the business relationship, in order to determine whether those transactions or activities appear unusual or suspicious. The Company also takes reasonable measures to establish the source of wealth and the source of funds.
3.1 Customer Service Department Email:
support@fullertonmarkets.com