We discussed the cash sales in Thailand and the ACDD requirements taking the opportunity to review the current practice in the light of the R&M CDD migration.
We were informed on the following:
1. The value of the cash sales (including those conducted via telesales) are low and tended to be one-off and mainly from first time potential Industrial customer for own use / testing. The number of such orders average around 50 per month with an average value of less than $1k per order and only make up less than 0.5% of the total annual turnover of Thailand lubes.
2. These cash sales are recorded via several cash sales account (reported by business channels) which enable visibility of the customer orders eg. Names, address and order value.
3. The nature of the orders would require a quick turnaround time for an order to be confirmed within the same business work day which may not be fulfilled within the R&M CDD committed turnaround time of 8 working hours.
In view of the above, we agreed that:
1. Given the low value, ad-hoc infrequent nature of this cash sales and with no customer master data record intended to be set up, CDD should be exempted for these customers. (Action: Li Ping, by 15 July to obtain an explicit E&C confirmation of this exemption)
2. Business be informed on the heightened money laundering risk associated with cash transactions coupled with higher standard of ACDD compliance activities in recent years, and therefore cost to serve this cash sales customer, that the cash sales (& telesales) model be reviewed periodically and should in most instances be referred to our distributors to serve. (Action: Samut, by 15 July)
3. As mitigation, Finance to review once every 6 months for any exceptions to the current norm. If the frequency of buying on cash increases (eg. if exceed 3 times over a 6-month period), then consider setting up a permanent account for the customer. (Action: Samut)