In the last weeks, the Monetary Authority of Singapore (“MAS”) published several updates, most importantly it published the amended Notice SFA 04-N02 to Capital Markets Intermediaries on Prevention of Money Laundering and Countering the Financing of Terrorism (“SFA04-N02”) and Guidelines to Notice SFA 04-N02 on Prevention of Money Laundering and Countering the Financing of Terrorism – Capital Markets Intermediaries (“Guidelines on SFA04-N02”).

The amendments to Notice SFA04-N02 and the Guidelines on SFA04-N02 reflect, to a large extent, practices highlighted by the MAS in previous guidance papers. Nonetheless, financial institutions, including external asset managers (“EAM”) must closely analyse the amendments and compare their policies, procedures and practices with the new requirements. Material amendments include the following:

• Money laundering includes proliferation financing.
• Financial institutions must include all trust relevant parties as defined in paragraph 2.1 of MAS Notice TCA-N03 in their due diligence of trusts.
• Lists of information required from beneficial owners and intermediate owners have been introduced.
• MAS’ expectations on the corroboration of the source(s) of wealth have been included in the Guidelines on SFA04-N02.
• Financial institutions are expected to submit suspicious transaction reports (“STRs”) within five business days, in case of sanctions, within one business day.

The MAS also announced the closure of its reviews from the large money laundering case (SGD 3bn) that was disclosed in August 2023. On 4 July 2025, the MAS announced composition penalties amounting to SGD 27.45m in total on nine financial institutions for breaches in AML/CFT requirements in relation to the case. A few days earlier, on 27 June 2025, the MAS also announced composition penalties amounting to SGD 960,000 in total on five major payment institutions for breaches in AML/CFT requirements.

On 3 July 2025, the MAS further announced the revocation of the capital markets services licence of Xen Capital Asia Pte. Ltd. and reprimand of its executive director. The company had failed to submit regular returns, missed notifications on material changes and the payment of its corporate fee, and failed to put in place an adequate compliance function.

With that in mind, EAMs must not forget to submit their quarterly returns for 2Q2025 by 14 July 2025. They also need to submit the confirmation regarding holders of effective control of their business by 1 August 2025, as requested in Circular CFD 01/2025. Finally, the MAS has sent out surveys, including the 2025 ML/TF risk assessment survey. EAMs should check on pending surveys.