# Internal Policies, Procedures & Controls (IPPC) — Jewellery Dealer Skeleton
**GJPA free template · v0.9 (demonstration)** — pre-mapped to the structure of MinLaw ACD's Compliance Toolkit guidance for PSPM regulated dealers. Replace every `[BRACKET]`. This skeleton does not constitute legal advice; align the finished document with the PSPM Act, its Regulations, the current Code of Practice, and ACD's own templates at acd.mlaw.gov.sg before adoption.

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**FIRM:** [Registered dealer name] · **UEN:** [ ] · **ACD registration no./class:** [ ] · **Outlets covered:** [ ]
**Compliance officer (2+ premises: must be SC/PR):** [name, title, contact] · **Approved by:** [ ] · **Date:** [ ] · **Review date:** [annual]

## 1. Risk assessment (business-wide)
- Nature, scale, customers, products, delivery channels, payment methods
- Higher-risk factors identified: [cash sales ≥ S$20,000 · tourist clientele · resale-value buyers · remote-directed buyers …]
- Conclusion of latest ML/TF risk review: [ ] (review at least annually and on major change)

## 2. Customer due diligence (CDD)
- When triggered: cash transaction ≥ S$20,000; suspicion; higher-risk per §1 [list firm-specific triggers]
- Identification & verification: [ID types accepted; who verifies; how recorded]
- Beneficial ownership & purpose of transaction: [when asked; how recorded]
- Enhanced due diligence (EDD) triggers & measures: [ ]
- Non-face-to-face / online sales handling: [ ]

## 3. Name screening
- Lists screened against: [UN, MAS TSOFA, EU/US/UK as firm adopts] · Frequency: [at onboarding / periodic] · Tool/manual: [ ]

## 4. Cash transaction reports (CTR)
- Threshold: cash ≥ S$20,000 (single or linked) · Who files: [ ] · Channel: [SONAR/police] · Retention of filings: 5 yrs

## 5. Suspicious transaction reports (STR)
- Red flags monitored (attach GJPA Red-Flag Counter Card list + firm-specific)
- Internal escalation path: staff → [compliance officer] → decision & filing via [STRO/SONAR]
- Tipping-off prohibition: written acknowledgement by ALL staff (see §7)

## 6. Record keeping
- CDD records & transaction documents: minimum 5 years · Storage: [ ] · Retrieval SLA on ACD request: [ ]

## 7. Staff training & awareness (the statutory duty)
- All staff: AML-Aware (or equivalent) within [30] days of hire, refreshed annually — register of completion kept
- Compliance officer & senior staff: Practitioner/CO-level training [frequency]
- Training records: [where kept] — evidence for ACD inspection

## 8. Governance & review
- IPPC owner: [compliance officer] · Approval: [management] · Annual review & version log below
- Related-party & franchise/consignment arrangements: [ ]

| Version | Date | Change | Approved by |
|---|---|---|---|
| 0.1 | [ ] | First adoption | [ ] |