Playeum's Anti-Money Laundering (AML) and
Countering the Financing of Terrorism
(CFT) Policy & Procedures
1. Introduction
This policy outlines the procedures that Playeum Ltd adopts to prevent its involvement in money laundering (ML) and the financing of terrorism (FT). It aligns with Singapore’s legal framework and international best practices.
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2. Scope
This policy applies to Board Directors, Advisors, officers, staff, volunteers, and any person acting on behalf of Playeum Ltd.
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3. Legal & Regulatory Compliance
Playeum Ltd is committed to complying with the following laws and regulations:
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Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (CDSA)
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Terrorism (Suppression of Financing) Act (TSOFA)
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United Nations Act and related regulations
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4. Governance & Responsibilities
The Governing Board of Directors are ultimately responsible for AML/CFT compliance.
The charity shall appoint a Principal Officer for AML/CFT responsible for:
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Overseeing policy implementation
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Coordinating training
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Liaising with authorities
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Filing Suspicious Transaction Reports (STRs) where necessary
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5. Risk-Based Approach
Playeum Ltd adopts a risk-based approach to assess and mitigate AML/CFT risks. Risk factors may include:
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Geographical risks
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Donor or partner risk profile
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Transaction type and size
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6. Due Diligence Measures
The charity shall implement appropriate due diligence (DD) based on risk. This includes:
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Identity verification of donors and partners’ donations from S$10,000 onwards
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Background screening using public databases or the ISCA panel
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Enhanced due diligence for high-risk transactions
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7. Red Flag Indicators
Examples of suspicious activities include:
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Anonymous or unusually large donations
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Donations through third parties
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Requests for refunds or use of crypto assets
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Donations from high-risk or sanctioned regions
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8. Suspicious Transaction Reporting (STR)
All staff must report suspicious transactions to the Principal Officer. Where necessary, an STR will be filed with the Suspicious Transaction Reporting Office (STRO).
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9. Training & Awareness
Playeum Ltd shall conduct AML/CFT training for Board, staff, and Playmakers/volunteers to raise awareness and ensure compliance with this policy.
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10. Review and Updates
This policy shall be reviewed annually or when significant regulatory changes occur. Revisions must be approved by the Board.