Clifford Chance

Singapore’s anti-money laundering landscape has seen a flurry of major developments in recent weeks, underscoring the Monetary Authority of Singapore’s ("MAS") tough stance on financial crime. Here are 3 key takeaways.

1. Recent enforcement actions

MAS has imposed composition penalties totalling S$27.45 million on nine financial institutions ("FIs") and S$960,000 on five Major Payment Institutions ("MPIs"), following breaches of Anti-Money Laundering and Countering the Financing of Terrorism ("AML/CFT") requirements.

The FIs were penalised on 4 July 2025 for their involvement in a major high-profile 2023 money laundering case involving more than S$3 billion in assets. MAS found shortcomings in customer risk assessments, failures to trace sources of customers' wealth, and insufficient monitoring of transactions flagged as suspicious. AML/CFT policies were inconsistently implemented.

The MPIs (which are licensed to provide cross-border money transfer services) were penalised on 27 June 2025 for inadequate customer screening against money laundering/terrorism financing ("ML/TF") information sources, insufficient customer identify verification, and incomplete transfer information for cross-border wire transfers.

This marks the first reported instance of MAS enforcing penalties specifically on MPIs under the Payment Services Act 2019 for AML/CFT breaches, while the penalties on FIs constitute the second-largest cumulative penalty imposed for such breaches. These enforcement actions demonstrate MAS' robust enforcement of AML/CFT requirements, and its commitment to maintaining Singapore's reputation as a secure and reliable financial hub. Heightened scrutiny on the payment services industry in particular is driven by recent growth in cross-border money transfers.

2. New regulations, supervisory expectations and guidance

Recent amendments to AML/CFT Notices and Guidelines for FIs have come into effect as of 1 July 2025. These amendments were made in the aftermath of the MAS' consultation in April 2025. Key amendments include the following:

• Clarify timing on the filing of a Suspicious Transaction Report ("STR"): The MAS observed that industry practices with respect to time taken for review and investigation to establish suspicion vary, depending on the complexity of the case. The MAS has clarified in the Guidelines that the filing of an STR should not exceed 5 business days after suspicion was first established, unless the circumstances are exceptional or extraordinary. In cases involving sanctioned parties, FIs should file the STRs as soon as possible, and no later than 1 business day after suspicion was first established.
• Clarify that ML includes proliferation financing ("PF"), and that the ML/TF assessments carried out by FIs should include PF risk assessments.
• In relation to trusts – expanding the scope of "trust relevant parties" to which AML/CFT checks are to be conducted. "Trust relevant parties" now include a "protector", a "class of beneficiaries", an "object of power" and "any other persons with the power under the legal arrangement instrument or by law” to deal with the property.
• Clarify that where necessary, ML/TF information sources used for screening should include pertinent search engines used in countries or jurisdictions closely associated with the person screened, and screening should be conducted in the native language(s) of the person screened.
• Clarify assessments on source of wealth ("SoW"): SoW includes seed money that generated subsequent wealth and gifts or other assets. SoW information should give an indication, to the extent practicable, about the entire body of wealth that the customer and beneficial owner would be expected to have, and how the customer and beneficial owner acquired the wealth. Information regarding SoW and source of funds should be corroborated.
• Clarify that after reporting suspicion in relation to a customer or a transaction for that customer, where further suspicion is raised in relation to the customer or any transaction for that customer, an assessment should be conducted on whether the filing of a further or supplementary STR to report the further suspicion is warranted.
• Inclusion of characteristics of a higher-risk shell company that FIs should consider as examples of potentially higher-risk categories.

These developments further the three aims of MAS' enforcement approach published in its latest Enforcement Report, namely: (a) early detection of misconduct and breaches of laws; (b) effective deterrence; and (c) shaping business and market conduct. Looking ahead, MAS will continue to provide AML/CFT guidance to FIs and take robust enforcement action, with a focus on cross-border collaboration and digital asset misconduct. 

The AML/CFT Industry Partnership (ACIP), a public-private partnership addressing money laundering and terrorism financing risks facing Singapore, has recently issued in May 2025 its paper on Best Practices in Relation to Risks in Wealth Management and Industry Perspectives on Best Practices for Source of Wealth Due Diligence, providing further guidance to FIs.

MAS has published an AML/CFT supervisory expectations from recent inspections for FIs in October 2024 and announced an upcoming information paper with industry-specific guidance for payment services providers.

3. Bottom line: Impact on compliance frameworks

FIs and MPIs should proactively review and strengthen their compliance frameworks. FIs should update their compliance frameworks in line with latest MAS Notices, Guidelines and supervisory expectations, and ensure robust implementation of their policies. MPIs should stay alert for MAS’ upcoming information paper and be ready to swiftly align with new enforcement guidelines. Relationship managers are the frontline defense against ML/TF risks, so vigilance and up-to-date training are essential.

This is an important and timely reminder for MPIs and FIs to tighten governance and embed best practices, keeping pace with Singapore's evolving AML/CFT regulatory landscape.