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papmall® Safeguard

papmall® Safeguard

What is papmall® Safeguard

papmall® Safeguard is designed to allow us to better protect you, support you and your accounts from fraud and financial crime. To do this we need to ensure that all the information we hold for you or your business is correct, complete and up-to-date. Changes in regulations may also mean that we require some additional information which we have not previously asked you to provide.

  • Check and review all our customer accounts to check we have all the details we need.
  • Be in touch to confirm, update or request new information.

Personal Customers

If you're a personal customer we're likely to need 2 types of documents from you: to confirm your identity and to confirm your address. Occasionally we may need more information than this.

Business Customers

If you're a business customer the documents we need will depend on the size and nature of your business. However we are likely to need to confirm your legal entity structure, your beneficial owners and countries you do business with.

What we will do with your data?

The sole purpose of gathering this information is so that our systems and processes can protect both our customers and papmall® against financial crime. We take our obligation to protect your data very seriously, so all the information you provide will be subject to papmall®'s high data and security standards. The intent is only to use this information for your protection and will NOT be used by any third parties for marketing purposes.

What has financial crime got to do with me?

Financial crime can affect anyone and everyone. Your support will go a long way to help us do business safer.

What are Sanctions?

Sanctions are a policy tool which national governments and organizations such as the United Nations and European Union use to constrain and deter perceived threats to their security, or to conform international conduct to recognized international standards. Sanctions help to stop crimes like terrorism, drug trafficking and arms dealing by imposing restrictions on the business that banks can do with specific people, corporations or countries and the names of these are clearly listed on things like the Office of Foreign Assets (OFAC) sanctions list.

Why is financial crime an increasing concern?

At papmall®, addressing financial crime globally has long been one of our main priorities.

However criminal activity has become increasingly sophisticated in recent years, and fraudsters, money launderers and others have attempted to target global networks.

Improving the way we share and manage customer information will help us fight against the risk of financial crime. After all, it's our duty to ensure that you can do business with us safely, securely, and confidently.

What has financial crime got to do with you or your business?

As the world becomes more and more connected and information moves around at a greater pace, there are unfortunately greater opportunities for criminals to misuse the financial system.

A key defence against money laundering is to prevent accounts being opened in false identities. We also sometimes need to verify where funds are from as part of our ongoing efforts to track our customers' legitimate funds and to protect them from financial crime. Criminals will try to appear to be law-abiding citizens or businesses and therefore we need to request documentary evidence from all of our customers in order to fully protect them and their accounts.

Why are you asking for all this information? Don't you already have it?

As well as acting to safeguard our customers, papmall® has a commitment to meet regulatory and legal requirements by ensuring that the information we hold is up-to-date, complete and accurate. You might have already provided some of this information prior to this request, but to stay one step ahead of fraud and financial crime, we need to ensure we have your most up-to-date information.

What information do I need to provide?

The request you receive from us will detail all the information required, in most cases, this will include a certified copy or original document verifying your residential address. For some of our customers, we may also require a certified copy of your identification documentation (e.g. a valid passport). We'll advise exactly what you'll need to provide when we contact you. In certain cases, we can only accept original documents which must be sent to us by post.

Why do you need information about my Source of Funds and Source of Wealth?

Regulatory and legal obligations require us to understand where funds are coming from and going to. This also helps us to protect you from fraud and financial crime.

What will happen if I don't provide this information?

We are required by our regulators to have this information. If we don't receive your up-to-date information we may no longer be able to provide you with our services. If you are having trouble gathering the information, need more time or have any further questions, please let us know and we will do our best to help.

Who can certify my documents?

The following people can certify photocopies of your documents, on the sight of the original document:

  • Bank Manager of a licensed, regulated bank
  • Embassy Consulate or High Commission Official of the country of issue of the documentation
  • Lawyer or Notary Public*
  • A Member of the Judiciary
  • Actuary* of the country of issue of the documentation
  • Accountant or Tax Adviser*

*Who is a member of a recognised professional body

If you provide original utility bills to confirm your address, these do not need to be certified. We regret that we will not be able to return these documents to you.

How do I certify my documents?

Your documents must be certified within the last three months and be in English. We can only accept certified copies that have been translated into English, providing both the foreign and English copies are certified as required.

How can I send my documents to you?

Once your documents are certified, please send them with your completed Personal Information Form to the following address:

papmall® statement on conduct


papmall® approaches to conduct is designed to ensure that through our actions and behaviors we deliver fair outcomes for our customers and do not disrupt the orderly and transparent operation of our business. Conduct is the critical component within all business activities including, including but not limited to strategy, business models and planning, our culture and behaviors including staff recruitment/performance management, our interaction with customers, our products and services, our business operations, and our governance and oversight processes.

Our approach to conduct is key to winning and retaining our customers’ trust and loyalty. Focus on conduct is integral to papmall®’s values and business principles and supports the Group strategy for sustainable growth and streamlining of business processes and procedures.

papmall® has defined global outcomes relating to conduct which must be delivered by global businesses, global functions, and Operations, Services and Technology, each responsible for conduct within the scope of their activities, and must develop and maintain approaches, tailored to their markets and operations, which deliver the required global conduct outcomes.

Global conduct outcomes

Strategy and Business Models

  • Our strategy, business models, and the decisions we make deliver fair treatment of customers and do not disrupt market integrity.
  • Culture and Behaviours
  • Our culture supports our people and empowers them to consistently do the right thing for our customers and markets in which we operate.
  • Our people are competent and committed to the fair treatment of customers and not disrupting the integrity of markets.
  • We are open to challenges, we acknowledge when things go wrong, we fix things and we learn from our mistakes.
  • We reward and incentivise performance, behaviours and attitudes which deliver the fair treatment of customers and uphold market integrity.


  • We know our customers and understand their needs – we actively listen to them and ask the right questions.
  • Our products are designed to meet the different needs of our customers, to be competitive and to be understandable.
  • Our products and services provide a balanced exchange of value between papmall® and our customers.
  • Throughout our sales and servicing we are efficient, transparent and customer-focused.
  • We manage our products and services so that our customers’ experience is in line with the expectations we set.


  • We seek to prevent and will proactively identify actions and behaviours that constitute market misconduct, and respond appropriately.
  • Trades are executed in a timely, clear and controlled manner ensuring that optimal execution is achieved for our customers and that papmall® trades are not manipulative.
  • We manage conflicts of interest and appropriately handle information to reduce the opportunity for misuse
  • Governance and Oversight
  • Our governance framework provides effective oversight of how we fairly treat customers and uphold market integrity.
  • We engage with regulatory bodies in a timely, open and transparent manner.

Activity and decision making within each global business, global function, and papmall® Operations, Services and Technology is expected to provide positive contribution to the global conduct outcomes, to ensure appropriate delivery of these outcomes.

Complaints handling

Our commitment to the highest standards of conduct and their embedding within our day to day activities is illustrated for example by our policy relating to complaints handling, which supports outcome:

We are open to challenge, we acknowledge when things go wrong, we fix things and we learn from our mistakes

Our global complaints policy sets out clear standards for:

  • The processes by which we investigate and resolve complaints in a timely, unbiased, and effective manner
  • Providing appropriate training to staff on our complaints processes, emphasising the need for empathy with customers
  • Ensuring customers are aware of how to make a complaint via a variety of channels (for example via relationship managers, face to face, telephone, on-line, in writing)
  • Resolving complaints at first point of contact wherever possible, and where this is not possible, providing an acknowledgement to the customer clearly setting out next steps
  • Ensuring customers are kept regularly informed of progress to resolve the complaint
  • Providing responses to customers upon completion of an investigation, clearly detailing the outcome and including, where appropriate, details of remedial action and any redress
  • Notification to customers of any available rights of referral or appeal if the customer is dissatisfied with the handling of, or response to, the complaint
  • Regular review of any “root causes” of complaints received to identify and address any systemic issues, and to inform process improvements where applicable
  • Monitoring the quality and efficiency of our complaints handling, including adherence to relevant local regulatory requirements

Product governance and sales

This conduct commitment is further illustrated by our policy and procedures in respect of product governance and sales which support the customer pillar outcomes, and encompass standards for:

  • The design, approval and ongoing maintenance of appropriate products/services, matched to customer needs, knowledge and experience
  • Customer communications that are clear, fair and not misleading – for example highlighting risks and benefits in equal proportion
  • Procedures where advice is provided and where advice is not provided
  • Ongoing services for customers, post-sale
  • Regular reviews of products to ensure they remain fit for purpose, and comply with applicable laws and regulatory requirements
  • Sensitivity to, and support for, customers who are, or may become, vulnerable by reason for example of illness, disability, bereavement, or other changes in life circumstances
  • Fair treatment of customers during account closure or product withdrawal/maturity, for example in terms of communication of what is happening and what alternatives are available
  • Oversight of any third party manufacturers or distributors of our products
  • Development and maintenance of our peoples’ training and competency, and applicable licences and regulatory approvals

Our Charter

Our Charter makes clear that if our staff have concerns that the standards contained in our policies and procedures, or any other aspects of our conduct are not being adhered to, they can speak up – for example:

  • Direct to their line manager, HR or Regulatory Compliance, or
  • Anonymously through papmall® Confidential our multi-channel, confidential, disclosure and follow-up investigation service.



PAPMALL LIMITED. has an active Supervisory Board under Compliance Officer, and the implementation of AML - CFT Program handled by AML - CFT Officer and all the team members (“MLRO”) which has been appointed by the Management. The MLRO is responsible for adherence to the applicable AML - CFT Program derived from AML - CTF procedure. PAPMALL LIMITED. has created a set of policy and procedures concerning general AML standards and principles. The governance ensures that the standards are implemented into day-to-day operational activities. All policy and procedures are published on accessible media so it can be accessed by all employees. They are subject to periodical review to ensure their conformity with recent and updated AML - CFT regulations. The scope of this policy covers all aspects of the Implementation of Anti Money Laundering and Counter-Financing Terrorism Prevention Program, namely:

  1. Active supervision of the Board of Directors;
  2. Policies and Procedures;
  3. Internal Control;
  4. Information Management System; and
  5. Human Resources and Training.


PAPMALL LIMITED. has implemented know your partner procedure to assure all kinds of partners are subject to identification and verification process. The know your partner procedure has been implemented in all business units. The goals are to have sufficient information and data about all partners’ profiles, whom they deal with, and also the Ultimate Beneficial Owners (UBOs). The procedures include mandatory documents requirements, enhanced due diligence for politically exposed persons (PEPs) and partners from high risk businesses or countries, name screening, and the ongoing monitoring and updating data of all existing parnters. PAPMALL LIMITED. shall refuse to support or has to close an existing parnter, if the following:

  • Cannot fix a reasonable belief that it knows the true identity of the partner and/or UBOs and/or the nature of business concerning the identification of the partners are not met;
  • Known and/or suspected the utilization of fake documents;
  • Assets that are known or suspected to be the proceeds of criminal activity;
  • Enter into business relationships with individuals or entities known or suspected
  • to be a terrorist or a criminal organisation or listed on sanction lists;
  • Maintain anonymous accounts or accounts operate for shell banks.


PAPMALL LIMITED. has an obligation to report cash transactions with a certain amount based on relevant regulations, suspicious transactions/activities, and international fund transfers. Suspicious transactions must be handled and escalated with the approval of the Compliance Officer prior to reporting to the regulator.


The AML - CFT Entity Risk Assessment is prepared by conducting inherent risk assessment activities, establishing risk tolerance, formulating mitigation and risk control measures, residual risk evaluation, applying a risk-based approach, and reviewing and evaluating approaches based on risk. AML - CFT MLRO identifies, assesses, and understands the risks of money laundering and or criminal acts of Terrorism Financing based on the partner’s country or geographical factors, products, services, transactions or distribution channels (delivery channels).


Sanctions Compliance Implementation is important in PAPMALL LIMITED. activities. PAPMALL LIMITED.'s obligations to establish restrictions and controls on the movement of goods, services, and partners’ funds were transacted through the products and services that were provided by PAPMALL LIMITED. Sanctions Compliance implementation goal is to keep PAPMALL LIMITED. from compliance risk, operational risk and reputational risk exposure. PAPMALL LIMITED. implements AML - CFT Sanctions procedure as a form of risk mitigation and guidance to relevant working units. The implementation is based on PAPMALL LIMITED. and Sanctions regulations issued by the government/local jurisdictions, international institutions / multilateral and clearing countries.


PAPMALL LIMITED. has to record all data and or information regarding partners’ documents, partners’ companies and/or its financial transactions (if any). PAPMALL LIMITED. maintains partners’ documentations for a minimum of 5 (five) years, notwithstanding longer retention as required. PAPMALL LIMITED. will provide information and/or documents to competent authorities as ordered by laws and regulations, when required.


PAPMALL LIMITED. has implemented AML - CFT training program for all staff. PAPMALL LIMITED.’s training program is tailored to the operations and business unit to assure all staff are aware of different patterns, methods, techniques, and typologies of money laundering or terrorist financing which may occur in daily operational activities. The training programs cover policy and procedures for the implementation of AML - CFT Program as well as roles and responsibilities of employees to assist in the eradication of money laundering or terrorist financing.


PAPMALL LIMITED. has an effective internal control system. PAPMALL LIMITED.’s AML - CFT Program is subject to independent control by Internal Audit function. The control demonstrates the adequacy of policy, procedures, internal monitoring, and responsibilities of working units associated with the implementation of AML - CFT Program. This Policy is an integral part of papmall® Singapore Pte. Ltd’s Anti-Money Laundering and Counter Financing Terrorism Procedure and shall take effect from 01 January, 2021.

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