Consultation Paper on the Proposed Amendments to Anti-Money Laundering and Countering the Financing of Terrorism Notices (8 April 2025)

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The proposed amendments will apply across the financial sector and variable capital companies (VCCs), and are expected to take effect from 30 June 2025.

A summary of the key amendments are as follows:

1. Expansion of ML definition: Clarifies that money laundering (ML) includes proliferation financing (PF), requiring ML/TF risk assessments to include PF risk assessments. This requirement should not in substance be something new or unfamiliar to Financial Institutions (FIs) and VCCs.
2. Trust relevant party definition: Broadens the definition in MAS Notice TCA-N03 to include a “protector”, a “class of beneficiaries”, “object of a power” and “any other persons with the power under the legal arrangement instrument or by law” to deal with the property under the legal arrangement or vary the legal arrangement.
3. Additional information for trust relevant parties: Specifies that additional information, such as identity and control information, is required for trust relevant parties.
4. Suspicious transaction report (STR) timelines: Clarifies that STRs should be filed no more than 5 business days after suspicion is first established, and within 1 business day for cases involving sanctioned parties.
5. STR investigation timelines: No prescribed specific timelines but expects FIs and VCCs to implement robust controls and processes to ensure the timely review of suspicious transactions and mitigation of ML/TF concerns identified.
6. Submission of STR to MAS: To only submit upon MAS request.
7. Other amendments in AML/CFT guidelines: Clarifies supervisory expectations on screening, source of wealth (SoW) and source of funds (SoF) establishment, and characteristics of higher-risk shell companies. A summary of the key amendments are as follows:

For the full details, please refer to the MAS website https://www.mas.gov.sg/publications/consultations/2025/consult-paper-on-aml-notice-and-guideline-amendments

Disclaimer: The information, views or opinions expressed are provided for general information and should not be relied upon as legal or professional advice.