AML/CFT is back! In its Consultation Paper on the Proposed Amendments to Anti-Money Laundering and Countering the Financing of Terrorism Notices for Financial Institutions and Variable Capital Companies, the Monetary Authority of Singapore (“MAS”) is proposing updates to its anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) regulations. AIWM has submitted a response to the consultation.

Most amendments transfer previous expectations from guidance papers to the notices and guidelines. For example, financial institutions will need to establish and independently verify the source of wealth of wealth management customers. However, the devil is in the details. For example, the amendments request financial institutions to provide guidance to their staff to identify indicators of fraudulent or tampered data, documents or information, and conduct screening in the native language(s) of the person screened and on pertinent search engines used in countries or jurisdictions closely associated with the person screened. Importantly, the persons related to trusts and other legal arrangements that financial institutions must identify are expanded, and the timeline to submit suspicious transaction reports (“STRs”) will be reduced to 5 days, or 1 day in case of sanctions. Financial institutions must keep a close eye on these proposed amendments. The MAS plans to put them in effect by 30 June 2025.

In addition, the MAS published its Enforcement Report 2023/2024. The MAS key areas of focus were market abuse, financial services misconduct, money laundering – related control breaches, and implementation of new investigative powers. The most important section for external asset managers (“EAMs”) is anti-money laundering. In two examples, the MAS reiterates senior management’s responsibility for the adequacy of the financial institution’s AML/CFT framework and its execution. AML/CFT controls will remain a focus of the MAS’ enforcement in 2025/2026.

Finally, holders of a capital markets services (“CMS”) licence whose financial year coincides with the calendar year are reminded to submit their financial statements and annual MAS returns by 31 May 2025.