On 15 July 2014, the Monetary Authority of Singapore (the “MAS”) issued a consultation paper with proposed amendments to the MAS Notices on Prevention of Money Laundering and Countering the Financing of Terrorism (the “Notices”). The changes aim to ensure that the anti-money laundering and countering of terrorism financing (“AML/CTF”) regime is effective, relevant and in line with international best practices and FATF’s (Financial Action Task Force) latest recommendations.

The proposed changes will affect banks, merchant banks, finance companies, money-changers and remittance licence holders, life insurers, capital markets intermediaries, financial advisers, approved trustees, trust companies, holders of stored value facilities and non-bank credit or charge card licensees (collectively, the “FIs”).

Comments on the proposed changes must be submitted to the MAS by 14 August 2014. Some of the key changes proposed are set out below.

  • FIs will be required to identify and assess the overall money laundering and terrorism financing risks faced by them at institutional level, and to take commensurate steps to mitigate these risks effectively.
  • Banks, merchant banks and finance companies will be required to perform customer due diligence (“CDD”) when effecting or receiving funds by wire transfer that exceeds S$1,500 for any customer who has no business relations with them.
  • The Notices will elaborate on the cascading measures that FIs need to undertake to identify and verify the identities of beneficial owners of non-individual customers, such as companies and trusts.
  • There will be an express requirement for FIs to screen their customers, their beneficial owners and connected persons against relevant money laundering and terrorism financing information sources, as well as lists and information provided by the MAS and any relevant Singapore authorities.
  • A risk-based approach will be introduced for FIs, in determining whether to perform enhanced CDD or the extent of enhanced CDD to be performed, for specified categories of politically exposed persons, their family members and close associates.
  • There will be a new Notice for non-bank credit or charge card issuers which will require such issuers to comply with AML/CTF measures applicable to the other FIs.

Reference materials

The following materials relating to the consultation paper are available from the MAS website www.mas.gov.sg: