The equilibrium price calculation is a crucial aspect of SGX Reach’s trading algorithm, particularly during opening, closing, and adjust phases. The algorithm prioritizes maximizing tradable volume and minimizing imbalance. When market orders are present and create a surplus on one side, the equilibrium price is determined by adding one tick to the side with the market order surplus. This adjustment reflects the immediate pressure from the market orders. In scenarios where the highest tradable volume and lowest imbalance occur at multiple prices, the algorithm considers market pressure (buy or sell) to determine the equilibrium price. If both buy and sell pressure or nil pressure exists, the equilibrium price is set closest to the last traded price or, if unavailable, to the lowest price within the overlap. This entire process ensures fair and efficient price discovery, aligning with the principles outlined in SGX ST Practice Note 8.2.1 and relevant sections of the CMFAS RES4 syllabus.

Under Singaporean law, specifically the MAS Act, financial institutions bear a significant responsibility in preventing financial crimes. A core component of this responsibility is adhering to targeted financial sanctions issued under the United Nations Security Council Resolutions, which are legally binding in Singapore through MAS Regulations. These regulations mandate that financial institutions must immediately freeze the funds and assets of designated individuals and entities, and they are prohibited from engaging in transactions or providing financial services related to these designated parties or sanctioned activities. Furthermore, financial institutions are obligated to report any information regarding funds or assets owned or controlled by designated individuals or entities to MAS. Failure to comply with these regulations can result in substantial penalties, including fines up to $1 million. Therefore, proactively screening clients against lists of designated individuals and entities is crucial for averting involvement in AML/CFT activities.

According to the Securities and Futures Regulations (SFR), specifically Section 16 and Section 17, a CMS licence holder is obligated to treat customer funds with utmost care and diligence. The regulations mandate that all money received on behalf of a customer must be considered as belonging to that customer and must be deposited into a designated trust account no later than the next business day after receipt. This requirement ensures the segregation of customer funds from the firm’s own assets, providing a layer of protection for the customer’s investments. Furthermore, the trust account must be maintained with specified financial institutions, such as a bank licensed under the Banking Act, a merchant bank approved under the MAS Act, or a finance company licensed under the Finance Companies Act. This ensures that the funds are held with reputable and regulated entities. The commingling of customer funds with the firm’s own funds is strictly prohibited, as is the use of customer funds for the firm’s own purposes, such as margin or guarantee for transactions. The regulations also allow for the commingling of funds from different customers into the same trust account, provided that the firm maintains separate accounting records for each customer’s funds. This allows for efficient management of customer funds while ensuring transparency and accountability.

The Central Depository (Pte) Limited (CDP) acts as a bare trustee, holding book-entry securities for the collective benefit of depositors. This arrangement ensures that while CDP manages the securities, the beneficial ownership remains with the investors. Securities are immobilized at CDP, and ownership transfers occur via book-entry, streamlining the settlement process. The physical certificates are held by a CDP-nominated custodian bank. This setup is crucial for maintaining the integrity and efficiency of the Singapore securities market. The linkage between trading accounts and direct securities accounts is a standing instruction, allowing seamless debiting and crediting of securities based on instructions from SGX-ST members. This process is vital for the smooth operation of trades executed on the SGX, ensuring that investors’ transactions are accurately reflected in their securities accounts. This is in line with regulations set forth by MAS to ensure proper handling of securities.

According to SGX-ST Rule 12.20 and Practice Note 12.20.1, soft dollar commissions are permissible under specific conditions. These conditions include that the goods and services received must reasonably assist in providing services to the customer, proper records of the goods and services must be maintained, and appropriate internal controls and procedures must be in place. However, certain goods and services are explicitly excluded, such as travel, accommodation, and entertainment expenses, general administrative goods and services, membership fees, employees’ salaries, and direct money payments (excluding referral fees under a referral agreement). The key principle is that the arrangement should not compromise the customer’s interests or breach any rules or regulatory requirements. In this scenario, providing a high-end television for personal use does not meet the criteria for acceptable soft dollar receipts, as it does not assist in providing services to the customer and could be seen as compromising the customer’s interests. Therefore, accepting the television would be a violation of SGX-ST rules regarding soft dollar commissions, potentially leading to penalties under SGX-ST Rule 12.20.1.

The scenario describes a situation involving a potential client, Mr. Tan, whose business activities and affiliations present several red flags for money laundering and terrorism financing (ML/TF). The fact that Mr. Tan operates a personal investment company, which is inherently exposed to higher ML/TF risks, coupled with his reluctance to meet in person and the use of a limited power of attorney, raises concerns. Furthermore, the involvement of multiple jurisdictions with varying levels of AML compliance, including Belize (considered high-risk), adds complexity and necessitates enhanced scrutiny. According to MAS Notice SFA 04-N02, financial institutions must conduct thorough due diligence on clients, especially when dealing with high-risk entities or jurisdictions. This includes verifying the client’s identity, understanding the nature and purpose of the business relationship, and conducting ongoing monitoring of transactions. The combination of these factors warrants a high-risk classification, triggering enhanced due diligence measures to mitigate potential ML/TF risks. Ignoring these red flags could expose the financial institution to regulatory sanctions and reputational damage, highlighting the importance of a robust risk assessment framework.

SGX-ST Rule 10.3 explicitly states that offenses related to accessing foreign markets without proper authorization or in violation of specified conditions are not compoundable and are subject to a mandatory minimum penalty. This stringent approach underscores the seriousness with which SGX-ST views compliance with regulations governing access to foreign markets. The rationale behind this non-compoundable nature and mandatory minimum penalty is to deter unauthorized access and ensure that trading members and their representatives adhere strictly to the prescribed rules and conditions. This helps maintain market integrity and prevents potential disruptions or unfair practices that could arise from non-compliance. The rule aims to create a level playing field and protect the interests of all market participants by enforcing a consistent and rigorous standard of conduct. Therefore, any violation of this rule will result in the imposition of a mandatory minimum penalty, reflecting the gravity of the offense.

SGX-ST Rule 12.4.1 mandates that Trading Members must secure written authorization from a customer before accepting orders from a third party acting on the customer’s behalf. This requirement ensures that the customer is aware of and consents to the third party’s trading activities, protecting the customer’s interests and maintaining market integrity. Failing to obtain this written authorization constitutes a violation of SGX-ST rules and can result in penalties. The rule aims to prevent unauthorized trading and potential misuse of customer accounts. The written authorization serves as a clear record of the customer’s consent and the scope of the third party’s trading authority. This is crucial for compliance and dispute resolution. The rule underscores the importance of due diligence and adherence to regulatory requirements in the securities industry in Singapore, as governed by the Securities and Futures Act (SFA).

According to the Securities and Futures (Licensing and Conduct of Business) Regulations (SFR (LCB)) and SGX-ST rules, CMS licence holders are obligated to provide monthly statements of account to their customers. These statements must detail securities transactions, the status of assets held in custody, asset movement, account balances, and financial charges. SGX-ST rules specify that these statements should be sent by the first week of the following month, unless there’s no change from the previous statement. However, there are exceptions. A member isn’t required to send a monthly statement if the information is already provided by a clearing house, there’s no change in the account, or the customer is an Accredited Investor or a related corporation who has real-time electronic statements available and has agreed to use them, or has requested in writing not to receive monthly statements. Failing to comply with SFR (LCB) Section 40(1), (2), or (3) can result in a fine not exceeding $50,000 upon conviction. SGX-ST Rule 12.7.1, which pertains to sending monthly statements within the stipulated timeline and including the required information, is not compoundable.

SGX-ST Rule 13.4.1 emphasizes the precedence of customer orders over those of trading members or prescribed persons. This rule aims to prevent conflicts of interest and ensure fair treatment of customers. A trading representative must not prioritize their own trades or those of related parties when a customer’s unexecuted order exists on the same terms. The exceptions to this rule are narrowly defined to maintain its integrity. Specifically, the rule does not apply if the trading representative lacks access to customer order flow information, if the customer’s order has specific conditions preventing its execution, or if the transaction occurs under prescribed conditions. Violations of this rule are considered serious and are subject to a mandatory minimum penalty, reflecting the importance of maintaining market integrity and customer trust. The rule aims to prevent front-running, where a trading member uses knowledge of a customer’s order to profit unfairly.

According to the CPFIS guidelines, corporate bonds eligible for investment under the CPFIS-OA scheme must meet specific criteria. These include being offered by companies incorporated in Singapore and listed on the SGX MainBoard. Additionally, the bonds should not be offered exclusively to institutional or accredited investors under Sections 274 or 275 of the SFA, ensuring accessibility to CPF members. Trading restrictions in the secondary market are not permitted, and the bonds must have a minimum credit rating of A2 by Moody’s, A by Standard and Poor’s, or A by Fitch. Furthermore, a prospectus compliant with the Securities and Futures Act requirements must be issued, or if exempted, an information memorandum detailing the terms, risks, and other relevant information must be available to CPF members. This ensures transparency and informed decision-making for CPF investors. The rationale behind these criteria is to protect CPF members’ retirement savings by ensuring that investments are in relatively stable and well-regulated instruments.

According to MAS Notice SFA 04-N02 on Prevention of Money Laundering and Countering the Financing of Terrorism – Capital Markets Intermediaries, a CMS licence holder must not establish business relations or undertake any transaction if there are reasonable grounds to suspect that the assets or funds are proceeds of drug dealing, criminal conduct, or related to terrorism financing. In such cases, the CMS licence holder must not proceed with the transaction and is obligated to file a Suspicious Transaction Report (STR) with the relevant authorities, extending a copy to MAS for informational purposes. This is a critical step in preventing financial crimes and adhering to regulatory requirements in Singapore’s financial sector. Ignoring such suspicions and proceeding with the transaction would be a direct violation of anti-money laundering (AML) and counter-terrorism financing (CTF) regulations, potentially leading to severe penalties and reputational damage for the CMS licence holder.

SGX-ST Rule 4.5A.3(1)(b) explicitly states that offenses under this rule are not compoundable and are subject to a mandatory minimum imposable penalty. This means that if a trading member violates the rule, they cannot negotiate a reduced penalty through a settlement or compromise. The penalty is predetermined and must be imposed at a minimum level. This stringent approach underscores the importance SGX-ST places on adherence to its rules and regulations, particularly those designed to maintain market integrity and protect investors. The non-compoundable nature of the penalty ensures consistent enforcement and serves as a strong deterrent against potential violations. The rule aims to promote a fair, orderly, and transparent market by ensuring that all participants are held accountable for their actions and that there are no exceptions or preferential treatment in the application of penalties. The mandatory minimum imposable penalty further reinforces this commitment by setting a baseline level of punishment that cannot be lowered, regardless of the circumstances.

CMS license holders in Singapore are required to adopt a risk-based approach when onboarding clients, as mandated by MAS Notice SFA 04-N02 on Prevention of Money Laundering and Countering the Financing of Terrorism. This approach involves assessing various risk factors to determine the level of due diligence required for each client. Key risk factors include the client’s country of origin, the nature of their activities, the size and source of their wealth, and any unusual transaction patterns. Transactions involving jurisdictions with inadequate AML/CFT measures, as identified by organizations like the Financial Action Task Force (FATF), also elevate the risk profile. PEPs (Politically Exposed Persons) inherently carry a higher risk due to their potential for corruption. The ultimate goal is to dynamically score ML/TF risks, allowing for appropriate monitoring and immediate action when necessary, in compliance with Singapore’s regulatory framework aimed at preventing financial crimes.

The ‘no-cancellation range’ is designed to prevent erroneous trades from disrupting the market. According to SGX-ST Rule 8.6.4A, this range is determined by two methods, and the wider of the two is applied. The first method involves calculating a range based on 20 minimum bid sizes above and below the reference price. The second method establishes a range of 95% to 105% of the reference price. The reference price is typically the price of the last good trade, but SGX-ST can use an alternative if the last trade price is unavailable or unreliable. If no reliable reference price exists, SGX-ST may not establish a no-cancellation range. This mechanism ensures that genuine errors can be addressed while preventing market manipulation or unwarranted trade cancellations. Understanding the calculation and application of this range is crucial for maintaining market integrity and fairness, aligning with the regulatory objectives of the SGX-ST.

According to the Securities and Futures Act (SFA) and the Securities and Futures Regulations (SFR), specifically SFR(LCB) 39, CMS licence holders are mandated to maintain comprehensive records of their business operations. This includes detailed records of all proprietary transactions, encompassing the description and quantity of assets, the price and fees associated with each transaction, the transaction and settlement dates, the counterparty’s identity, and the realized or unrealized gains or losses. Furthermore, CMS licence holders must meticulously document all income and expenses, liabilities (including contingent liabilities), and assets, specifying where these assets are held and whether they are pledged as security against loans. SGX-ST Rules also reinforce these requirements, emphasizing the need for complete records and audit trails to demonstrate compliance with SGX-ST Rules, the SFA, and SFR. Failure to maintain accurate and complete records can result in penalties, including fines up to $50,000 under the SFA and SFR(LCB).

According to the CPF Investment Scheme (CPFIS), statutory board bonds must adhere to specific criteria to be eligible for investment using CPF funds. These conditions are designed to protect CPF members and ensure the integrity of the investments. A critical requirement is that the bonds are listed on the SGX, providing transparency and liquidity. Furthermore, they must be traded in Singapore dollars to mitigate currency risk for CPF members. Importantly, these bonds cannot be exclusively offered to institutional or accredited investors under Sections 274 or 275 of the Securities and Futures Act (SFA), ensuring accessibility to retail investors. Trading restrictions in the secondary market are also prohibited to maintain fair access for all investors. Finally, a prospectus complying with SFA requirements must be issued, or if exempted, an information memorandum detailing the terms, risks, and other relevant information must be available to CPF members, ensuring informed investment decisions. These measures collectively aim to safeguard CPF members’ investments while providing access to suitable investment opportunities.

Under Singapore’s regulatory framework, particularly concerning the prevention of financial crimes, financial institutions are mandated to conduct thorough screening of both prospective and existing clients against lists of designated individuals and entities. This requirement is crucial for proactively averting involvement in Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) activities. The Monetary Authority of Singapore (MAS) emphasizes this obligation through its regulations and guidelines, ensuring that financial institutions remain vigilant in identifying and mitigating risks associated with designated parties. Failing to comply with these regulations can result in significant penalties, including substantial fines. The screening process involves comparing client information against lists provided by the UN Security Council and MAS, which identify individuals and entities subject to targeted financial sanctions. This proactive measure is a cornerstone of Singapore’s efforts to maintain the integrity of its financial system and combat financial crimes effectively, as outlined in the Capital Markets and Financial Advisory Services (CMFAS) Examination Module 1A.

According to SGX-ST rules, a Trading Member is obligated to send monthly statements to its customers, detailing securities transactions, asset status, and account activity. However, this requirement is waived under specific conditions. One such condition is when the customer is an Accredited Investor and real-time electronic statements are made available, and the customer has agreed to using these electronic statements. This exception recognizes the sophistication and access to information that Accredited Investors typically possess, allowing for a more streamlined communication process. The key here is that both conditions must be met: the customer must be an Accredited Investor, and they must have access to and have agreed to use real-time electronic statements. The rule aims to balance regulatory compliance with practical considerations, acknowledging that certain investors may prefer or be better served by alternative methods of receiving account information. Failing to provide the required statements when none of the exemptions apply can result in penalties under the Securities and Futures Act (SFA) and SGX-ST rules.

Under the Securities and Futures Act (SFA) in Singapore, a corporation intending to conduct regulated activities in the capital markets, such as dealing in securities, must obtain a Capital Markets Services (CMS) license from the Monetary Authority of Singapore (MAS). This licensing requirement ensures that entities operating in the capital markets meet certain standards of competence, financial soundness, and integrity, thereby protecting investors and maintaining the integrity of the market. The SFA mandates that individuals acting on behalf of CMS license holders in carrying out regulated activities must be appointed as representatives. MAS supervises CMS license holders and their representatives through a framework of legal and regulatory requirements to ensure they are well-managed and resilient against systemic risks. Failing to obtain the necessary CMS license before engaging in regulated activities constitutes a breach of the SFA and can result in penalties, including fines and legal sanctions. Therefore, compliance with licensing requirements is crucial for any entity operating in Singapore’s capital markets.

According to the Monetary Authority of Singapore (MAS) guidelines and the CMFAS RES4 syllabus, financial institutions must be vigilant in identifying suspicious transactions that could indicate tax evasion or other illicit activities. Several red flags are outlined to aid in this detection process. One significant indicator is when a customer’s transactions involve jurisdictions known for tax evasion, especially if the funds are quickly reinvested back into the original country after passing through a tax haven. This behavior raises concerns about potential attempts to conceal assets or evade tax obligations. The lack of a clear or convincing purpose for opening accounts in Singapore, particularly when coupled with inconsistent sources of deposits and withdrawals, further heightens suspicion. These factors, when combined, suggest a deliberate effort to obscure the true nature and origin of the funds, warranting closer scrutiny and potential reporting to the relevant authorities under Singapore’s anti-money laundering and counter-terrorism financing regulations. The key is to assess the overall context of the transactions and the customer’s behavior to determine if there is a reasonable basis for suspecting illicit activity, aligning with the requirements of the Financial Intelligence Reporting Act (FIRA).

When a CPFIS member passes away, their CPFIS investments and cash in the Investment Account are not covered under CPF nomination and become part of the deceased’s estate. These assets are then subject to the Probate and Administration Act, meaning they can be used to satisfy the deceased member’s creditors’ claims. CPFIS insurance policies with revocable nominations bypass the estate administrator/executor process and are paid directly to the beneficiaries. However, irrevocable nominations are not allowed for CPFIS insurance policies. The estate administrator/executor must produce the Letters of Administration/Grant of Probate to claim the investments from the agent bank or product providers. Once the member dies, the protection afforded to CPFIS investments and cash balances under the CPF Investment Scheme ceases, and creditors can make claims against these assets. Therefore, understanding the implications of death on CPFIS investments is crucial for financial advisors.

Under the Securities and Futures Act (SFA), specifically concerning insider trading regulations, several exceptions and defenses exist. One such defense, outlined in SFA Section 230, pertains to licensed broker-dealers executing transactions on behalf of a principal. This exemption applies when the broker-dealer, holding a Capital Markets Services (CMS) license for dealing in securities, executes a trade on a stock market based on a principal’s instruction. Critically, this defense is valid only if the principal’s instruction was unsolicited by the CMS license holder or its representative, meaning the broker-dealer did not actively encourage or suggest the trade. Furthermore, the principal must not have received advice from the CMS license holder or its representative regarding the transaction. Finally, the principal and the CMS license holder or its representatives must not be ‘associates,’ indicating a lack of close connection or influence that could compromise the integrity of the transaction. This provision aims to protect broker-dealers from liability when they act solely as conduits for their clients’ independent trading decisions, ensuring that they are not penalized for actions over which they had no influence or advisory role, thereby maintaining a fair and efficient market under Singaporean law.

According to MAS regulations, specifically SFA 04-N12, Trading Members in Singapore have a responsibility to offer investor education, particularly to young investors and those interested in Specified Investment Products (SIPs). These courses aim to enhance awareness of trading decisions and improve investment choices. When a customer requests advice concerning an unlisted SIP, even after a positive Customer Knowledge Assessment (CKA), the CMS license holder or exempt financial institution should provide advice. If the customer declines advice, this decision must be documented in writing. The customer must also acknowledge in writing that they are responsible for ensuring the suitability of the product and confirm their decision to proceed without advice. The CMS license holder or exempt financial institution should warn the customer in writing about the implications of choosing not to receive advice. This process ensures that customers are fully informed about the risks and responsibilities associated with investing in complex products, aligning with the regulatory requirements for investor protection in Singapore’s financial markets.

Securities hawking, as defined under Section 309 of the SFA, involves offering securities during unsolicited meetings. The key element is the lack of prior consent or inquiry about the customer’s interest before presenting the investment product. The prohibition aims to protect retail clients from high-pressure sales tactics. In the scenario, approaching a customer waiting for a credit card application and immediately pitching an investment product without first obtaining consent or inquiring about their interest constitutes securities hawking. This is because the meeting’s initial purpose was unrelated to investments, and the sales pitch was unsolicited. Options involving institutional or accredited investors are incorrect because the securities hawking prohibition does not apply to offers made to these types of investors, as per Sections 304 and 305 of the SFA. Similarly, if the customer had already expressed interest in investment products, the interaction would not be considered unsolicited. The penalties for securities hawking, as stipulated in Section 309(4) of the SFA, include fines and/or imprisonment.

According to the Securities and Futures (Licensing and Conduct of Business) Regulations (SFR(LCB)), specifically Section 32 regarding Custody Agreements, a CMS license holder must ensure certain conditions are met when placing a customer’s assets in a custody account. One of these conditions explicitly states that the custodian must not permit any withdrawal of assets from the custody account, except for specific purposes. These purposes are limited to transferring the asset to any person entitled to it or meeting the customer’s obligations arising from dealing in securities, trading in futures contracts, or leveraged foreign exchange trading by the holder for the customer. This regulation aims to protect the customer’s assets and ensure that withdrawals are only made for legitimate and agreed-upon purposes, preventing unauthorized or inappropriate use of the customer’s assets. The CMS license holder has a responsibility to ensure compliance with this regulation to maintain the integrity of the custody arrangement and safeguard the customer’s interests. Ignoring this regulation could lead to regulatory sanctions and reputational damage for the CMS license holder.

According to the SFA 99B(1), any individual who conducts a regulated activity without being an appointed, provisional, or temporary representative is in violation of the SFA 99B(1). The penalties include a fine not exceeding $50,000, imprisonment for a term not exceeding 12 months, or both. Additionally, for a continuing offense, there is a further fine not exceeding $5,000 for each day the offense continues after conviction. This regulation is in place to ensure that individuals conducting regulated activities are properly authorized and supervised, thereby protecting investors and maintaining the integrity of the financial markets in Singapore. The penalties serve as a deterrent against unauthorized individuals engaging in regulated activities, which could potentially lead to financial misconduct or harm to investors. The SGX-ST also has rules in place to ensure that individuals are properly registered and comply with regulatory requirements.

According to the SGX-ST rules and SFR(LCB) regulations, a Trading Member is permitted to withdraw a remisier’s assets from a custody account only under specific circumstances. These include returning the assets to the remisier, utilizing the assets to settle any outstanding debts owed by the remisier to the Trading Member, or executing a transfer or withdrawal that is legally authorized. The Trading Member is obligated to notify the remisier of such withdrawals by the next business day. Depositing the remisier’s assets into the Trading Member’s operational account is not a permissible reason for withdrawal. This is to prevent commingling of funds, which is strictly prohibited under SGX-ST Rule 12.12.5. The rule aims to protect the remisier’s assets and maintain clear segregation of funds to ensure transparency and accountability in financial transactions. Failing to comply with these regulations can result in penalties, as outlined by SGX-ST.

The Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (CDSA) is a cornerstone of Singapore’s anti-money laundering (AML) and counter-terrorism financing (CTF) regime. Section 44 of the CDSA specifically addresses the offense of entering into an arrangement to facilitate the retention or control of benefits derived from criminal conduct. This section aims to prevent individuals from knowingly assisting others in concealing, transferring, or utilizing illicit funds. The key element is the knowledge or reasonable grounds to believe that the arrangement facilitates the retention or control of criminal benefits. The arrangement can involve various activities, such as concealing the funds, removing them from the jurisdiction, transferring them to nominees, or using them to secure funds or acquire property for the benefit of the person who derived the criminal benefits. This provision is crucial for disrupting money laundering networks and preventing criminals from enjoying the fruits of their illegal activities. It aligns with Singapore’s commitment to the Financial Action Task Force (FATF) recommendations and its efforts to combat financial crimes effectively. Failing to report such activities can result in legal repercussions under Singapore law.

Under the regulatory framework in Singapore, particularly concerning the prevention of financial crimes as outlined in the Capital Markets and Financial Advisory Services (CMFAS) Regulations, financial institutions must establish and maintain robust Know Your Customer (KYC) procedures. These procedures are designed to prevent money laundering and terrorism financing. A critical component of KYC is the ongoing monitoring of customer transactions. When a customer’s transaction patterns deviate significantly from their established profile without a reasonable explanation, it raises a red flag. This necessitates further inquiry to ascertain the legitimacy of the transaction. The Monetary Authority of Singapore (MAS) mandates that financial institutions report suspicious transactions to the Suspicious Transaction Reporting Office (STRO) of the Commercial Affairs Department (CAD). Failure to conduct adequate monitoring and report suspicious activities can result in regulatory penalties. The key is to ensure that the institution has a system in place to detect, investigate, and report unusual transactions, thereby contributing to the integrity of the financial system. This aligns with the requirements specified in the relevant MAS Notices on Prevention of Money Laundering and Countering the Financing of Terrorism.