KYC/AML: Source of Wealth

About This Course

In today’s competitive climate, private banking professionals faced a lot of challenges. One of the key to success include a better understanding of your clients and their source of wealth. Instead of ticking boxes without understanding the rationale and implications of doing so, this course will equip you with the knowledge and skill to assess and document the sources of wealth of your high net-worth clients.

Who Should Attend

  • Private banking heads
  • Private banking relationship managers
  • Private banking front office customer service officers
  • Wealth KYC team

Learning Outcomes

To enable Private Bankers and their support staff including KYC team to be competent and committed in assessing and documenting the source of wealth for private banking accounts.


  • Set – Short review of AML developments
  • Upset – Why must private bankers document source of wealth?
  • Reset – Private bankers, especially the front office has to take active ownership of ML risks

Review of AML requirements

  • Enhanced customer due diligence for private banking
  • MAS guidance on private banking controls on source of wealth

Source and verification

  • Typical source
  • Not so typical source
  • Supporting documents
  • Research and other means of verification
  • Special mentions
    • PEPs (Panama, 1MDB)
    • Country risk

Onboarding process

  • Getting the prospect to tell wealth story
    • Identify sources
    • Documentation
    • Other means of verification
  • Not scientific, but do not ignore your gut

Only by the book

  • Ticking the boxes
  • Going strictly by the rules
  • Generic rules vs special cases

Cases that went wrong

  • Analyse 2 or 3 cases
  • Staff can share actual or near misses, if any

Collateral benefit

  • Reduce cost of operation
  • Knowing customer needs — a marketing tool
  • Business opportunity, recommend appropriate products
  • Enhance long term customer relationship


  • Risk based approach
  • Continual process

Case studies/Role Play:

  • Onboarding process
  • Transaction review
  • Revisit with focus on source of wealth due diligence - “Replay the onboarding of a complex structure of 1MDB”

Jane Foo

LLB (Hons) (University of London)

Jane has over 25 years of banking experience in Compliance, Operational Risk and Audit across a broad spectrum of banking businesses, products and services. Her areas of expertise include Ethics & Compliance and Operational Risk & Audit.

Jane is currently the Director, Compliance of AMEX (Singapore Branch) and supports all the lines of business operating out of the AMEX Singapore Branch.

Prior to joining AMEX, Jane was the Head of Compliance, Retail and Wealth Management Divisions in ANZ Bank where she was involved in business compliance advisory, new product approvals, marketing approvals, incident reporting, compliance training, remediation of gaps in compliance breaches.

Jane was previously the Head of Control & Compliance in Citibank Singapore Limited from 2004 – 2009. In her role, she covered all product lines including Credit Cards, unsecured lending, mortgages, term loans, deposits, F/X, Wealth Management and insurance products. She supported both the consumer mass market as well as the higher end-premier markets. Jane also conducts training for new hires on Investment Advisory Regulations/Policies/Procedures & Code of Conduct and AML.

Jane started her banking career in United Overseas Bank in Group Internal Audit and was promoted as the Divisional Head, Operational Risk Management & Compliance Division for Group UOB.

Throughout her professional banking experience, she also served as the Chair at ABS Financial Crime Task Force and Chair at ABS Operational Risk Management Task Force.

Jane holds a LLB (Hons), University of London and B. Soc Science (2nd Uppers), University Science Malaysia.

David Teo

BA (Mass Communications), Curtin University of Technology, Australia

David has 7 years of experience of Compliance, Operational Risk and Internal Controls work in the banking and payments industry. His areas of expertise include Anti-Money Laundering and Operational Risk.

David is currently the Country Compliance Manager in a global money-changing and remittance service provider. His role covers a wide range of Compliance duties from drafting policies, transaction monitoring, STR filing, regulatory reporting, staff training and data protection.

David held the position of Assistant Vice President in United Overseas Bank’s Cards and Payments department previously. He was the AML representative for the line of business, addressing queries from various areas of the UOB group, such as Compliance, Operations, Internal Audit and the Senior Management Team. He was also the principal trainer for the business, ensuring that new regulations, policies, and processes were clearly briefed to management and front liners. His duties also included overseeing a team of junior officers for KYC quality assurance, transaction monitoring, investigation and STR filing.

During his time in UOB, he was credited with co-spearheading the full-customer base merchant remediation exercise to align the business with the requirements of MAS Notice 626. The massive customer base, complete with complex ownership structures, was fully remediated within a tight schedule of 1 year.

David holds a BA in Mass Communications from Curtin University of Technology, Australia and a Diploma in Multimedia Computing.

The Financial Training Scheme (“FTS”)

The Salmon Thrust CPD Series is aimed at raising the competencies of Covered Persons. This course is recognised under the IBF Financial Training Scheme. Completion of this course can be counted towards the fulfilment of the non-STS portion for CACS CPD.

The Financial Training Scheme (“FTS”) is a training incentive scheme supported by the Financial Sector Development Fund (FSDF). The scheme supports financial sector-specific training programmes that raise the competency of the financial sector.

All our programmes are approved for listing on the Financial Training Scheme (FTS) Programme Directory and are eligible for FTS claims, subject to all eligibility criteria being met. For latest development on the Funding Support for IBF FTS, please visit the Financial Training Scheme site.

Early Bird Discount

Enjoy 10% early bird discount when you register one (1) month before the course commencement date.

KYC/AML: Source of Wealth


S$ 650

Course Features
  • Duration
    1/2 Day
  • CPD
    4 Hours
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