Singapore

Plain English

Sets three operating principles for banks: customer/representative/connected-party/beneficial-owner diligence; high ethical standards and guarding against laundering or terrorist-financing links; and cooperation with Singapore law enforcement to the fullest extent possible. These are broad principles, not a substitute for the detailed controls below.

Obligation

Sets three operating principles for banks: customer/representative/connected-party/beneficial-owner diligence; high ethical standards and guarding against laundering or terrorist-financing links; and cooperation with Singapore law enforcement to the fullest extent possible. These are broad principles, not a substitute for the detailed controls below.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

Requires each bank to identify, assess and understand ML/TF risk across customers, their geographic connections, the bank’s operating jurisdictions, and its products, services, transactions and delivery channels. Footnote 3 expressly includes proliferation-financing risk.

Obligation

Requires each bank to identify, assess and understand ML/TF risk across customers, their geographic connections, the bank’s operating jurisdictions, and its products, services, transactions and delivery channels. Footnote 3 expressly includes proliferation-financing risk.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

Requires the bank’s paragraph 4.1 assessment to be documented, based on relevant factors, kept current and supported by a mechanism for giving the assessment information to MAS.

Obligation

Requires the bank’s paragraph 4.1 assessment to be documented, based on relevant factors, kept current and supported by a mechanism for giving the assessment information to MAS.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

Requires senior-management-approved controls to manage identified or authority-notified risks, monitoring and enhancement of those controls, enhanced measures for higher risks, and measures responsive to the bank’s risk assessment and relevant authority guidance.

Obligation

Requires senior-management-approved controls to manage identified or authority-notified risks, monitoring and enhancement of those controls, enhanced measures for higher risks, and measures responsive to the bank’s risk assessment and relevant authority guidance.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

Requires the bank to identify and assess ML/TF risks before new products or practices (including new delivery methods) and new or developing technology used with new or existing products.

Obligation

Requires the bank to identify and assess ML/TF risks before new products or practices (including new delivery methods) and new or developing technology used with new or existing products.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

Requires the assessment before launch or use, to the extent the Notice permits that use, and appropriate risk mitigation.

Obligation

Requires the assessment before launch or use, to the extent the Notice permits that use, and appropriate risk mitigation.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

Requires special attention in the paragraph 5.1–5.2 assessment to products, practices, delivery methods or technologies that favour anonymity.

Obligation

Requires special attention in the paragraph 5.1–5.2 assessment to products, practices, delivery methods or technologies that favour anonymity.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

Prohibits the bank from opening or maintaining either an anonymous account or an account under a fictitious name.

Obligation

Prohibits the bank from opening or maintaining either an anonymous account or an account under a fictitious name.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

Before establishing business relations or undertaking any transaction without opening an account, if the bank has reasonable grounds to suspect that customer assets/funds are proceeds of drug dealing or criminal conduct under the CDSA, or terrorism-related property under TSOFA, it must refuse the relationship/transaction and file an STR; it sends MAS a copy on request. Footnote 4 specifically cautions about CDSA section 57 tipping-off; it is not a general reporting exception.

Obligation

Before establishing business relations or undertaking any transaction without opening an account, if the bank has reasonable grounds to suspect that customer assets/funds are proceeds of drug dealing or criminal conduct under the CDSA, or terrorism-related property under TSOFA, it must refuse the relationship/transaction and file an STR; it sends MAS a copy on request. Footnote 4 specifically cautions about CDSA section 57 tipping-off; it is not a general reporting exception.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

The trigger is before establishing business relations or undertaking a transaction without opening an account, plus the stated reasonable grounds to suspect specified criminal proceeds or terrorism-related property. “Without opening an account” does not mean an unaccounted transaction. Footnote 4 points to CDSA section 57 tipping-off without importing its text.

Exceptions

Not recorded

Plain English

A bank must perform paragraphs 6-8 CDD when it establishes business relations; for a customer without existing business relations, when it conducts an ordinary transaction above S$20,000 (except the digital-token transactions in 6.3(c)), any digital-token transaction, any domestic wire regardless of value, a cross-border wire above S$1,500, or effects/receives digital tokens by value transfer. It must also do so on any ML/TF suspicion regardless of other thresholds and where previously obtained information is doubtful. Footnote 3 states that money-laundering-risk references include proliferation-financing risks. Paragraph 2.2 supplies the equivalent-currency and digital-payment-token threshold conversion rule.

Obligation

A bank must perform paragraphs 6-8 CDD when it establishes business relations; for a customer without existing business relations, when it conducts an ordinary transaction above S$20,000 (except the digital-token transactions in 6.3(c)), any digital-token transaction, any domestic wire regardless of value, a cross-border wire above S$1,500, or effects/receives digital tokens by value transfer. It must also do so on any ML/TF suspicion regardless of other thresholds and where previously obtained information is doubtful. Footnote 3 states that money-laundering-risk references include proliferation-financing risks. Paragraph 2.2 supplies the equivalent-currency and digital-payment-token threshold conversion rule.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Ordinary no-existing-business-relation customer transaction: value must exceed S$20,000, except paragraph 6.3(c) digital-token transactions. Any such digital-token transaction triggers CDD. For no-existing-relation customers, domestic wires trigger at any value; cross-border wires only above S$1,500; any value transfer of digital tokens triggers. Suspicion and doubts are independent overrides. Footnote 3 says ML-risk references include proliferation-financing risks. Apply paragraph 2.2’s threshold equivalent rule for other currencies and digital payment tokens.

Exceptions

Not recorded

Plain English

When the bank suspects transactions are related, linked or deliberately split to evade the paragraph 6.3(b) or (d) thresholds, it must aggregate them as one transaction.

Obligation

When the bank suspects transactions are related, linked or deliberately split to evade the paragraph 6.3(b) or (d) thresholds, it must aggregate them as one transaction.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

Requires the bank to identify every customer.

Obligation

Requires the bank to identify every customer.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

Requires minimum identity data for natural-person and entity/arrangement customers, including identifiers and addresses; for entities it also requires formation details, trust deed if any, purpose, administration location and governing form/powers.

Obligation

Requires minimum identity data for natural-person and entity/arrangement customers, including identifiers and addresses; for entities it also requires formation details, trust deed if any, purpose, administration location and governing form/powers.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

For a legal-person or legal-arrangement customer, requires identifying its connected parties and obtaining each person’s full name (including aliases) and unique identification number.

Obligation

For a legal-person or legal-arrangement customer, requires identifying its connected parties and obtaining each person’s full name (including aliases) and unique identification number.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

The bank must document the results of its paragraph 6.8A(a) assessment that customer ML/TF risk is not high and all measures taken under 6.8A(b) to try to obtain the connected party’s unique identification number. This documentation duty applies to the stated substitute-data pathway; it does not convert “not high” into the distinct low-risk test for simplified CDD.

Obligation

The bank must document the results of its paragraph 6.8A(a) assessment that customer ML/TF risk is not high and all measures taken under 6.8A(b) to try to obtain the connected party’s unique identification number. This documentation duty applies to the stated substitute-data pathway; it does not convert “not high” into the distinct low-risk test for simplified CDD.

Retain records

Data items: paragraph 6.8A(a) assessment results, all measures under paragraph 6.8A(b)

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

This documentation duty attaches to the paragraph 6.8A substitution: the customer risk was assessed as not high, and reasonable measures did not obtain the connected party’s unique identification number. Do not substitute the separate low-risk standard in paragraph 7.1.

Exceptions

Not recorded

Plain English

Requires reliable, independent verification of the customer’s identity; for an entity or arrangement, verification also covers legal form, existence, constitution and governing powers.

Obligation

Requires reliable, independent verification of the customer’s identity; for an entity or arrangement, verification also covers legal form, existence, constitution and governing powers.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

When one or more natural persons act for a customer in establishing business relations, requires the bank to identify each and obtain the listed personal particulars, then independently verify each identity.

Obligation

When one or more natural persons act for a customer in establishing business relations, requires the bank to identify each and obtain the listed personal particulars, then independently verify each identity.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

Requires documentary evidence of each representative’s appointment and verification that the person is authorised, using methods such as a specimen signature or electronic verification.

Obligation

Requires documentary evidence of each representative’s appointment and verification that the person is authorised, using methods such as a specimen signature or electronic verification.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

Where the substituted business address is used, requires reasonable steps to verify it using reliable, independent sources.

Obligation

Where the substituted business address is used, requires reasonable steps to verify it using reliable, independent sources.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

The bank must document the results of its paragraph 6.11A(a) assessment that customer ML/TF risk is not high and all measures under 6.11A(b) to try to obtain the representative’s residential address. Paragraph 6.11A permits the business address in place of the residential address only where its not-high-risk and reasonable-measures conditions are met. “Not high” is not the separate low-risk test for simplified CDD.

Obligation

The bank must document the results of its paragraph 6.11A(a) assessment that customer ML/TF risk is not high and all measures under 6.11A(b) to try to obtain the representative’s residential address. Paragraph 6.11A permits the business address in place of the residential address only where its not-high-risk and reasonable-measures conditions are met. “Not high” is not the separate low-risk test for simplified CDD.

Retain records

Data items: paragraph 6.11A(a) assessment results, all measures under paragraph 6.11A(b)

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

This documentation duty applies only to the paragraph 6.11A substitution where the bank assessed customer risk as not high and could not obtain the representative’s residential address after reasonable measures. Do not import paragraph 7.1’s low-risk test.

Exceptions

Not recorded

Plain English

Requires the bank to inquire whether a customer has a beneficial owner, subject to the express exemptions in paragraph 6.16.

Obligation

Requires the bank to inquire whether a customer has a beneficial owner, subject to the express exemptions in paragraph 6.16.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Not recorded

Exceptions

Not recorded

Plain English

Where a customer has one or more beneficial owners, the bank must identify them through the staged test. For a legal person, identify natural persons who ultimately own it; if ownership is doubtful or no natural person ultimately owns it, identify any natural persons who ultimately control or effectively control it; if none are identified through those limbs, identify natural persons with executive authority or an equivalent/similar position. For a trust, identify trust relevant parties, natural persons with ultimate ownership/control/effective control over the trust or relevant parties (including through chains), and each legal person or legal arrangement along such chain. For another legal arrangement, identify persons in equivalent positions. A chain entity is not thereby reclassified as a natural-person beneficial owner. For a class/characteristics-designated trust beneficiary, footnote 5 requires sufficient information to identify and verify that beneficiary before distribution or when the beneficiary seeks to exercise vested rights.

Obligation

When beneficial owners exist, identify them through the ownership, control and final executive-authority fallback for legal persons and the trust-relevant-party/natural-person/control-chain tests for legal arrangements. Identify legal persons and arrangements along trust chains without treating them as natural-person beneficial owners. For a trust beneficiary designated by class or characteristics, obtain enough information to identify and verify the beneficiary before a distribution or when the beneficiary intends to exercise vested rights.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Apply the sequential ownership, control and executive-authority fallback only as stated for legal persons; use trust relevant parties, natural-person control/ownership and all legal persons/arrangements in the chain for trusts; identify equivalent persons for other arrangements. Footnote 5’s identify-and-verify timing applies to a trust beneficiary designated by class or characteristics.

Exceptions

Not recorded

Plain English

For every person identified under paragraph 6.14, the bank must obtain the listed minimum data, not only data for a natural-person beneficial owner. For a natural person, this is full name and aliases, unique identifier, residential address, date of birth and nationality. For a legal person or arrangement, it is full name; registration/tax identifier; registered/business and, if different, principal-business address; constitution/incorporation/registration date and place; any trust deed or equivalent; purpose; place of administration; and legal form, constitution and governing powers. The trust-chain entities identified under 6.14 remain within this phrase.

Obligation

Obtain paragraph 6.14A’s minimum information for each person identified under 6.14, whether natural person, legal person or legal arrangement: the respective identity particulars, and for an entity/arrangement its identifiers, addresses, formation details, trust deed if any, purpose, administration place, legal form, constitution and governing powers.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

The data subject is each person identified under paragraph 6.14, including legal persons/arrangements along a trust control or ownership chain; do not narrow this to natural-person beneficial owners only.

Exceptions

Not recorded

Plain English

The bank must take reasonable steps to check the identity of every person brought within paragraph 6.14 against trustworthy information from independent sources, including documentary evidence or other data. If the identified person is a legal person or legal arrangement, it must also verify that person’s legal form, existence, constitution and governing powers using such reliable independent material. This includes identified chain entities and trust-relevant parties; it does not label each as a beneficial owner.

Obligation

Take reasonable steps, using reliable independent source data, documents or information, to verify the identity of each person identified under 6.14. For each such legal person or arrangement, also verify legal form, existence, constitution and governing powers.

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

Verification covers each person identified under paragraph 6.14, including legal persons/arrangements in trust chains; do not restrict the duty to persons categorized as beneficial owners.

Exceptions

Not recorded

Plain English

The bank must document the results of its paragraph 6.14C(a) assessment that customer ML/TF risk is not high and all measures under 6.14C(b) to try to obtain the beneficial owner’s unique identifier and/or residential address. Paragraph 6.14C permits the stated date-of-birth, nationality and/or business-address substitutes only where its not-high-risk and reasonable-measures conditions are met. “Not high” is not the separate low-risk test for simplified CDD.

Obligation

The bank must document the results of its paragraph 6.14C(a) assessment that customer ML/TF risk is not high and all measures under 6.14C(b) to try to obtain the beneficial owner’s unique identifier and/or residential address. Paragraph 6.14C permits the stated date-of-birth, nationality and/or business-address substitutes only where its not-high-risk and reasonable-measures conditions are met. “Not high” is not the separate low-risk test for simplified CDD.

Retain records

Data items: paragraph 6.14C(a) assessment results, all measures under paragraph 6.14C(b)

Applies to

Firm types

Bank in Singapore (Notice 626 scope)

Business lines

Not recorded

Customer types

Not recorded

Stages

Not recorded

Conditions

This documentation duty attaches only to the paragraph 6.14C substitution: assessed customer risk is not high and reasonable measures did not obtain the beneficial owner’s unique identification number and/or residential address. Do not import paragraph 7.1’s low-risk test.

Exceptions

Not recorded