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Singapore’s Anti-Money Laundering (AML) Requirements: A Sector-by-Sector Breakdown

The Monetary Authority of Singapore (MAS) has outlined anti-money laundering (AML) requirements for various sectors in the country. In this article, we will break down these requirements by sector, highlighting similarities and differences across industries.

Similar Requirements Across Sectors

In general, AML requirements are similar across Financial Institutions (FIs) and Designated Businesses. Both must implement procedures regarding:

Risk assessment and risk mitigation
Customer due diligence (CDD)
Recordkeeping
Suspicious transaction reporting
Other internal policies, procedures, and controls

AML Requirements Vary Across Sectors

The AML requirements vary across sectors, with FIs and Designated Businesses with higher exposure to money laundering (ML) risks subject to more stringent requirements.

PSPs are required to register and apply for a PSP licence under the Payment Services Act 2019. They must also meet the AML/CFT requirements under MAS Notice PSN01 Prevention of Money Laundering and Countering the Financing of Terrorism. Cryptocurrency companies, or DPT service providers, are also obliged to register and apply for a PSP licence under the PSA. They must meet the AML/ CFT requirements under MAS Notice PSN02 Prevention of Money Laundering and Countering the Financing of Terrorism - Digital Payment Token Service.

Exceptions

Services relating to limited purpose digital payment tokens (DPTs) and limited purpose e-money are excluded from the requirements imposed under the PSA. Additionally, NFTs (non-fungible tokens) are not specifically regulated in Singapore, but existing AML requirements may apply depending on their underlying characteristics.

Recordkeeping and Reporting

FIs and Designated Businesses must retain CDD information and other data for a minimum of five years. PSM dealers must maintain records of cash transactions exceeding S$20,000, as well as customer information, for a period of five years. PSPs must record adequate details of transactions that equal or exceed S$20,000 so that the transactions can be reconstructed. A CTR (Cash Transaction Report) must be submitted for cash transactions or designated transactions that exceed S$20,000 in a transaction (or in a day).

Conclusion

The MAS has outlined a sector-by-sector approach to AML requirements, with varying levels of scrutiny depending on the level of ML risk posed by each industry. Compliance is crucial to preventing money laundering and terrorism financing in Singapore.

Sources:

Payment Services Act 2019
Prevention of Money Laundering and Terrorism Financing Act (CDSA)
Precious Stones and Precious Metals (Prevention of Money Laundering and Terrorism Financing) Act 2019 (PSPMA)
Pawnbrokers Act 2015