The Monetary Authority of Singapore (“MAS”) issued a consultation paper on proposed amendments to the Anti-Money Laundering and Countering the Financing of Terrorism (“AML/CFT”) Notices and Guidelines, aimed at enhancing the financial sector's defenses against money laundering (“ML”), terrorism financing (“TF”), and proliferation financing “(PF”).
Key proposed amendments
- Inclusion of PF in ML definitions: MAS proposes to clarify that ML includes PF, and that risk assessments conducted by financial institutions (“Fis”) and variable capital companies (“VCCs”) must incorporate PF risk assessments. This aligns with international standards set by the Financial Action Task Force (“FATF”).
- Amendments to MAS Notice TCA-N03: Changes will align the wording of MAS Notice TCA-N03 with the Trustees Act 1967. This includes expanding the definition of "trust relevant party" to include protectors and classes of beneficiaries, reflecting recent legislative updates.
- Timeliness of Suspicious Transaction Reports (“STRs”): The guidelines will be updated to require that STRs are filed within 5 business days of establishing suspicion, with a stricter 1 business day requirement for cases involving sanctioned parties. This aims to improve the promptness of reporting suspicious activities.
Additional clarifications
- The MAS highlights that the requirement to assess PF risks is not new for most FIs and VCCs, as they have been expected to consider such risks in their compliance controls.
- The amendments to TCA-N03 will ensure consistency with industry practices and legal requirements, enhancing the identification and verification processes for trust relevant parties.
Consultation and implementation
MAS invites feedback on these proposed amendments from all regulated entities and interested parties, with submissions due by May 6, 2025. The amendments are expected to take effect from June 30, 2025.
These proposed amendments reflect MAS's commitment to maintaining an effective AML/CFT framework that aligns with international standards and addresses emerging risks in the financial sector. The focus on timely reporting and the inclusion of PF in risk assessments are critical steps towards bolstering the integrity of the financial system in Singapore.
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