Following the annual returns, at least for most external asset managers (“EAMs”), the Monetary Authority of Singapore (“MAS”) is already following up with additional surveys, such as the Survey of Services. Financial institutions should check MASNet for the respective circulars.

In May 2025, the MAS highlighted additional guidance on anti-money laundering (“AML”)/countering the financing of terrorism (“CFT”). The AML/CFT Industry Partnership (“ACIP”), a private-public partnership by the Commercial Affairs Department of the Singapore Police Force and the MAS with financial institutions, published “Best practices in relation to risks in wealth management” and “Industry Perspectives on Best Practices for Source of Wealth Due Diligence”. These papers provide valuable insights on different aspects of AML/CFT, such as non-face-to-face onboarding, or different types of sources of wealth. The paper on “Best practices in relation to risks in wealth management” also has a section on “Risks associated with External Asset Managers (EAM) or Financial Intermediary (FIM) engagement”.

Speaking of AML/CFT, EAMs should prepare themselves for the announced amendments of the Notice SFA 04-N02 to Capital Markets Intermediaries on Prevention of Money Laundering and Countering the Financing of Terrorism and the respective Guidelines by 30 June 2025 resulting from the recent Consultation Paper on the Proposed Amendments to Anti-Money Laundering and Countering the Financing of Terrorism Notices for Financial Institutions and Variable Capital Companies.