On 8 April 2025, the Monetary Authority of Singapore (MAS) issued a consultation paper seeking feedback on “Proposed Amendments to the Anti-Money Laundering and Countering the Financing of Terrorism AML/CFT Notices and Guidelines” applicable to Financial Institutions (FIs) and variable capital companies (VCCs). These changes aim to enhance Singapore’s AML/CFT measures and align with international standards set by the Financial Action Task Force (FATF).  

Although the consultation period ended on 8 May 2025, financial institutions and stakeholders still have time to prepare for the changes. The proposed amendments are expected to take effect on 30 June 2025.  

What are the proposed amendments to Singapore’s AML/CFT rules?

Inclusion of Proliferation Financing (PF) Risks  

MAS proposes to clarify that money laundering (ML) includes proliferation financing (PF) and requires FIs and VCCs to carry out ML/TF risk assessments, including PF risk assessments. This aligns with the FATF Standards requiring FIs and designated non-financial businesses and professions to identify, assess, understand and mitigate their PF risks.  

Amendments to MAS Notice TCA-N03 

Following amendments to the Trustees Act 1967 implementing the revised FATF Recommendation 25, MAS proposes to amend the wording of MAS Notice TCA-N03. These changes will expand the definition of “trust relevant party” and clarify the requirements to identify all related parties to a legal arrangement and gather the necessary information.  

Furthermore, the amendments will require the collection of specific information about the legal arrangement, including the full name, unique identifier, trust deed, the purpose for which the legal arrangement was set up and the place where the legal arrangement is administered.  

Clarification of STR Filing Timelines  

MAS proposes that amendments to the AML/CFT Guidelines require that Suspicious Transaction Reports (STRs) should not exceed five business days after suspicion was first established, except in exceptional or extraordinary circumstances. For cases involving sanctioned parties and parties acting on their behalf or under their direction, FIs and VCCs must file the STRs as soon as possible, no later than one business day after suspicion is identified. 

Other amendments to the AML/CFT Guidelines

MAS also proposes further amendments relating to screening, source of wealth (SoW) and source of funds (SoF) establishment, and the characteristics of higher-risk shell companies that FIs and VCCs should consider as examples of potentially higher-risk categories. These modifications include enhancing screening accuracy with relevant search engines, improving information sharing across business units and reinforcing fraud detection measures.  

Additional updates further enhance the assessment of the legitimacy of the SoW and SoF, indicate when supplementary STRs may be required and include participation in a tax amnesty programme as a potential risk factor. The changes also update terminology to align with updated definitions.  

The proposed amendments apply across the financial sector, including the following: 

• banks 
• insurers 
• merchant banks 
• finance companies 
• payment service providers 
• direct life insurers 
• capital markets intermediaries 
• financial advisers 
• central depository 
• approved exchange and recognised market operators 
• approved trustees 
• trust companies 
• non-bank credit and charge card licensees 
• digital token service providers 
• VCCs  

Conclusion

The consultation paper highlights MAS’s continuous efforts to maintain a robust and transparent AML/CFT framework that complies with global standards. On top of that, the proposed amendments mark a significant step in improving the efficiency of AML/CFT policies throughout the financial industry.  

How we can help

As the intended effective date of the proposed changes approaches, FIs and VCCs should carefully examine the amendments, assess how they would affect existing practices and proactively work toward early implementation to ensure a smooth transition ahead of the deadline.   

Bolder Group is well-equipped to provide regulatory support services for financial institutions and variable capital companies. We will continue to follow developments and give further information as it becomes available to assist you in navigating these regulatory changes. 

If you have any questions, please get in touch with our Bolder Singapore representatives.  

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