Important Notice on Jurisdiction-Based Restrictions
As a regulated precious metals dealer supervised by the Singapore Ministry of Law, Silver Bullion is required to carry out identity checks, screening, and due diligence before opening any account, providing services, or entering into any transaction. In certain cases, these checks may be more extensive and ongoing.
Some jurisdictions are classified internationally as presenting higher risks of money laundering and terrorism financing or are subject to international sanctions. Where a customer is connected to such jurisdictions, we are required to perform enhanced verification, documentation review, and ongoing monitoring.
Given the level of documentation, review, and ongoing monitoring required, we are temporarily restricting the onboarding of new customers from these jurisdictions while we continue to enhance our processes.
Case-by-Case Onboarding
In limited cases, onboarding may still be considered only after Enhanced Customer Due Diligence (ECDD) has been completed and approved. Additional documentation, screening, ongoing monitoring, and transaction controls will apply.
As part of this process, we may be required to complete Enhanced Customer Due Diligence (ECDD). This may include collecting additional information and supporting documents to better understand the customer, the source of funds used for transactions, and the overall risk profile.
Depending on the circumstances, this may include:
- Source of Wealth (SOW), which explains how your overall wealth was accumulated over time
- Source of Funds (SOF), which explains where the specific funds for your transactions came from
- Employment or business information, including employer, role, or nature of business activities
- Supporting financial documents, such as bank statements, salary records, business income records, investment liquidation records, or property sale documents
- Additional identity, screening, or background checks, where required
All required verification must be completed and approved before any transaction may proceed.
Transaction Limits
Even after a S.T.A.R. Verified Account has been approved, annual transaction limits for purchases and sellbacks may apply as part of our regulatory and risk management framework.
Requests to increase these limits may be considered on a case-by-case basis. In such cases, we may require additional information and supporting documents to better understand the customer’s financial profile, expected transaction activity, and the purpose of the transactions.
Any increase remains subject to further due diligence and internal approval.
Affected Jurisdictions
The affected jurisdictions include those identified by the Financial Action Task Force (FATF) as higher risk, as well as jurisdictions subject to international sanctions.
As referenced at the time of publication, jurisdictions that FATF identified as Under Increased Monitoring include: Algeria, Angola, Bolivia, British Virgin Islands, Bulgaria, Cameroon, Côte d'Ivoire, Democratic Republic of Congo, Haiti, Kenya, Kuwait, Lao People’s Democratic Republic, Lebanon, Monaco, Namibia, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, Yemen.
As referenced at the time of publication, jurisdictions that FATF identified as High-Risk Jurisdictions Subject to a Call for Action include: Iran, Democratic People’s Republic of Korea (North Korea), Myanmar.
The current FATF lists are available at: https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html
Jurisdictions or regions subject to sanctions measures may include Russia, Belarus, and certain regions of Ukraine including Crimea, Donetsk, and Luhansk. Sanctions designations and restrictions are subject to change.
Review of Risk Framework
Silver Bullion reviews its risk appetite and internal policies regularly to ensure alignment with regulatory guidance and evolving risk conditions.
Onboarding criteria, verification requirements, and transaction controls may change from time to time in line with regulatory developments and internal risk assessments.