AML/CFT & KYC Policy (Website Statement)

Purpose and Scope

This AML/CFT & KYC Policy statement explains the controls STIDE applies to manage money laundering (“ML”), terrorism financing (“TF”) and proliferation financing (“PF”) risk in connection with STIDE’s advisory/arranging work on ASEAN-related private credit and structured finance mandates. ^[A]

This statement is directed to corporates and institutional/professional counterparties only. STIDE does not deal with retail clients or unaccredited individuals through its website or mandate intake processes. ^[A]

STIDE’s Role and Regulatory Perimeter (what we do / do not do)

STIDE acts as an arranger/structuring advisor and execution coordinator, not a lender. STIDE typically does not originate loans onto its own balance sheet, does not operate payment accounts for clients, and does not hold client assets as deposits. ^[A]

Because STIDE may influence which counterparties are brought together and may shape structures, flows and security, STIDE applies risk-based “gatekeeper” controls proportionate to its role and does not outsource AML/CFT responsibility to banks, law firms or other parties. ^[A]

STIDE monitors relevant regulatory and industry standards as reference points to remain compatible with counterparties’ expectations (including MAS AML/CFT notices applicable to regulated entities, such as MAS Notice SFA 04-N02 and MAS Notice FAA-N25, and successors). ^[2] STIDE also recognises the FATF Recommendations as the global AML/CFT standard for high-level framework alignment. ^[3]

Note: Any statement in this page describing laws, regulators or reporting channels is provided at a general level only, and does not constitute legal advice.

Risk-Based Approach (RBA) and Relationship Risk Categories

STIDE applies a risk-based approach (“RBA”) that calibrates the depth of due diligence and monitoring to the risk profile of the customer/counterparty, jurisdiction(s), sector, ownership/structure complexity, and transaction characteristics. STIDE maintains an enterprise-wide risk assessment which is reviewed at least annually and updated on material changes (e.g., new countries/sectors or major guidance changes). ^[A]

For relationship management, STIDE classifies relationships broadly into the following categories, with controls increasing by risk level: ^[A]

• Low risk: transparent ownership, reputable counterparties, straightforward structure and funding rationale.
• Medium risk: some complexity or cross-border exposure, but reasonable transparency and corroborating information available.
• High risk: elevated risk indicators (e.g., high-risk sectors/jurisdictions, complex layering, adverse information, PEP exposure) requiring Enhanced Due Diligence (“EDD”).
• Prohibited: relationships or activities STIDE will not knowingly onboard or continue (see Section 8). ^[A]

Who We Onboard / Counterparty Types

Depending on role in a mandate, STIDE may perform varying levels of KYC / Customer Due Diligence (“CDD”) on customers, counterparties and key transaction parties, including (as relevant): borrowers/sponsors, lenders/investors/funds/family offices, originators/NBFIs, guarantors/security providers, SPVs/holding companies/trusts, and introducers/intermediaries. ^[A]

KYC / CDD: What We May Request

CDD is performed, at a minimum: (i) before entering into an engagement/mandate with a borrower or sponsor; (ii) before presenting a borrower to specific investors; (iii) before entering any commercial arrangement with an originator or introducer; (iv) when doubts arise about previously obtained information; and (v) for any transaction/structure that appears unusual or high-risk. ^[A]

For corporate customers/counterparties, STIDE may request and verify (as applicable): legal name and registration details, registered address and principal place of business, ownership and control structure (including UBOs), directors and authorised signatories, and supporting corporate documents and registers. For UBOs/controllers, STIDE may request identifying particulars (including government-issued identification details) and information on the nature/extent of ownership/control. ^[A]

For SPVs/holding structures and trusts, STIDE may request minimum information such as trust deeds/shareholder agreements, UBO details, and the commercial purpose of the structure, and may assess the link between the structure and the underlying asset/transaction. Nominee arrangements without transparency and unjustified layering are treated as higher risk. ^[A]

For intermediaries/introducers, STIDE may request identity, licensing status (if applicable), business model and typical client base, and may require a written introducer agreement including AML clauses. High-risk indicators include fee arrangements contingent on avoiding KYC, reluctance to disclose information, or regulatory/dispute history. ^[A]

Enhanced Due Diligence (EDD): When required

EDD is applied where risk indicators warrant deeper scrutiny, including (non-exhaustively): PEP exposure, material adverse media, high-risk jurisdictions, complex multi-layered structures, and sectors with elevated ML/TF/PF risk. STIDE may require additional measures such as corroboration from independent sources, deeper source of wealth/source of funds information, enhanced approvals, and additional checks proportionate to risk. ^[A]

Screening: Sanctions, PEP and Adverse Media

STIDE screens counterparties (and, where relevant, UBOs/directors/key signatories) against sanctions and restricted-party lists. As a minimum, STIDE screens against UN sanctions lists and Singapore sanctions lists, and may screen additional regimes (e.g., OFAC, EU) where relevant to the transaction profile. ^{[A] [4]}

STIDE screens UBOs, directors and key signatories for PEP status. PEP hits require EDD and MLRO approval to proceed. STIDE conducts adverse media checks using credible public sources and/or third-party databases, and escalates significant negative findings for fact-checking and decisioning. ^[A]

Screening is conducted: at onboarding, upon KYC refresh, on trigger events (e.g., new adverse media or sanctions updates), and optionally by periodic batch screening (e.g., quarterly). Screening hits are categorised as false positives (documented and closed), potential matches (further investigation), or true positives (escalation and risk decisioning). ^[A]

Ongoing Monitoring and KYC Refresh

Suggested minimum KYC refresh intervals are: low risk every 3 years, medium risk every 2 years, and high risk annually (with earlier refresh on trigger events). ^[A]

Even as an arranger, STIDE monitors at least at a structural level that transaction flows remain broadly consistent with the designed structure, and that significant changes (e.g., new sponsors, unusual repayments, side agreements) are identified and assessed. Triggers for review or re-rating include material ownership changes, serious negative news or regulatory action, persistent failure to provide information, or significant deviations from expected cashflows. ^[A]

Suspicious Activity Escalation (internal process) and External Reporting Concepts

Any staff member who suspects ML/TF/PF or related crime must promptly document the concern, submit an Internal Suspicious Transaction/Activity Report to the MLRO (or delegate), and not inform the customer or counterparties. The MLRO assesses the suspicion, may obtain further information if needed, decides whether to file an STR/SAR with the relevant authority, and documents the decision and rationale. ^[A]

Singapore law contains reporting and disclosure-related provisions for suspicious transactions and terrorism financing, and public guidance indicates that STRs may be submitted to the Suspicious Transaction Reporting Office (“STRO”) via the SONAR platform in appropriate cases. ^[1]

STIDE will not assist any party to conceal, misrepresent or circumvent AML/CFT controls, and reserves the right to decline, suspend or terminate engagements where AML/CFT concerns are not satisfactorily addressed. ^[A]

Reliance on Third Parties and Licensed Partner Handoffs

Where regulated activities or custody/escrow arrangements are required, STIDE expects appropriately licensed or exempt third parties (e.g., banks, escrow agents, licensed intermediaries, counsel) to perform those functions. STIDE may rely on third parties for certain checks where appropriate, but retains responsibility for its own risk decisions and will seek sufficient access to underlying information and written confirmations as required for confidence in reliance. ^[A]

Record Keeping and Retention

STIDE maintains records of CDD/EDD information, screening results, risk assessments, escalations and decisions, and relevant communications and approvals. STIDE’s default retention approach is to retain relevant AML/CFT records for at least 5 years after the end of the relationship or completion of the transaction (as applicable), or longer where required or appropriate for legal, regulatory, dispute or audit reasons. ^[A]

Use of Technology, Data Controls and Confidentiality

STIDE may use secure electronic collection of documents, controlled-access storage, and screening tools/databases to support onboarding and monitoring, applying reasonable safeguards to protect confidentiality. No method of transmission or storage is risk-free; therefore STIDE does not warrant absolute security. Personal data handling is addressed in STIDE’s Privacy Policy.

Training, Awareness and Independent Review

STIDE provides AML/CFT training to personnel at induction and periodically thereafter (at least annually), proportionate to role. STIDE also conducts periodic reviews/testing of its AML/CFT framework, including independent review at intervals aligned to the organisation’s size and risk profile. ^[A]

Cross-Border Considerations (ASEAN)

STIDE operates on ASEAN and cross-border mandates where multiple legal regimes may be relevant. Customers and counterparties are responsible for compliance with applicable laws in all relevant jurisdictions. STIDE may apply additional controls where cross-border exposure increases risk or where counterparties (e.g., banks/funds) require higher standards as a condition of engagement. ^[A]

Updates

STIDE may amend, update or withdraw this statement (and related processes) to reflect changes in law, regulatory expectations, business model, products/services, or risk assessment outcomes. The “Last updated” date above indicates the most recent revision to this page.

Contact

General enquiries: contact@stide.asia
AML/CFT escalation (including reporting of concerns or red flags): compliance@stide.asia

Verification Required

Where STIDE-specific details are not stated in STIDE’s referenced policy document and cannot be verified from authoritative public sources, they are marked as [●] and must be confirmed before publication if you intend to include them as “hard facts” rather than internal-position statements.

Abbreviations / Glossary

• AML: Anti-Money Laundering.
• CFT: Counter-Financing of Terrorism.
• PF: Proliferation Financing.
• KYC: Know Your Customer.
• CDD: Customer Due Diligence.
• EDD: Enhanced Due Diligence.
• UBO: Ultimate Beneficial Owner.
• PEP: Politically Exposed Person.
• STR/SAR: Suspicious Transaction (or Activity) Report.
• STRO: Suspicious Transaction Reporting Office (Singapore).
• SONAR: Online STR filing platform used by STRO.
• MAS: Monetary Authority of Singapore.
• FATF: Financial Action Task Force.
• FI: Financial Institution.
• NBFI: Non-Bank Financial Institution.
• SPV: Special Purpose Vehicle.
• SoW/SoF: Source of Wealth / Source of Funds.
• MLRO: Money Laundering Reporting Officer.

Footnotes: [A] STIDE internal AML/CFT & KYC policy source. | [1] Singapore STR/SONAR reporting channel guidance. | [2] MAS AML/CFT notice reference pages (for regulated entities; used here as reference points). | [3] FATF Recommendations (global standard). | [4] Singapore/UN targeted financial sanctions concept and list sources.