AML Laws and Regulations for Accountants in Singapore
In a Nutshell
- An accountant in Singapore comes within the anti money laundering regime based on the nature of work.
- When a public accountant or an accounting entity prepares for or carries out certain defined activities, the work of the sector is supervised by the Accounting and Corporate Regulatory Authority.
- The binding rulebook is the Accountants (Prevention of ML, FT and PF) Rules 2023, made under the Accountants Act 2004 and in force from 1 July 2023. The Institute of Singapore Chartered Accountants pronouncement EP 200, carries the identical AML/CFT requirements for its members.
- Singapore’s 2024 assessment rates the accounting sector as moderate in money laundering risk. Around this core sit the criminal and sanctions statutes that bind every business, the national risk assessments, the professional and corporate laws an accountant works within, and the FATF standards.
AML Laws and Regulations for Accountants in Singapore
An accountant sees the financial life of a business from the inside, and that vantage point is exactly why the anti money laundering regime reaches the profession. This guide sets out the laws and regulations that apply to an accountant in Singapore, from the criminal statutes that make money laundering an offence to the specific rulebook the Accounting and Corporate Regulatory Authority enforces on accounting work that falls within the defined scope.
The framework is best read in layers. The criminal and sanctions laws sit at the base. Above them is the instrument an accountant works with when the engagement is in scope, the Accountants (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Rules 2023, together with the profession’s EP 200 pronouncement. Alongside these run Singapore’s national risk assessments, the Accountants Act that constitutes the profession, the corporate laws an accountant operates within, and the FATF standards behind the whole regime.
Because an accountant does not usually move a client’s money the way a bank does, its exposure is less the mechanical layering of funds than the risk of certifying accounts or engineering structures that give criminal money a respectable face. That shapes much of what follows, from how an accountant looks through to the beneficial owner of a client to how it questions a complex arrangement that has no commercial logic.
Singapore's Accounting Sector at a glance
As of 31 March 2023 there were more than 4,200 professional accountants in public practice in Singapore, of whom 1,210 were public accountants practising across 720 accounting entities (Money Laundering National Risk Assessment 2024, chapter 8.7).
Of about 29,000 members of the Institute of Singapore Chartered Accountants, only around 807, close to 3 percent, declared in 2023 that they perform activities scoped by the FATF, and about 95 percent of those already fall under an existing supervisor (ML NRA 2024, chapter 8.7).
Risk rating: the accounting sector is assessed as moderate for money laundering, because accountants seldom handle client monies, though they can lend legitimacy to falsified accounts or mask ownership through complex structures (ML NRA 2024, chapter 8.7).
Core AML Laws and Regulations for Accountants in Singapore
These statutes and sanctions regulations make money laundering, terrorism financing and proliferation financing offences and require every accountant to detect and report them. They bind an accountant directly.
The Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992
The CDSA covers Singapore’s money laundering offences and allows courts to confiscate criminal proceeds. For an accountant, the central duty is to report to the Suspicious Transaction Reporting Office once it knows or suspects that a client or an engagement involves criminal proceeds. This duty has itself put accountants before the courts. Alerting the client to that scrutiny is a separate tipping off offence.
The Terrorism (Suppression of Financing) Act 2002
Under the TSOFA it is a crime to raise, supply or handle property meant for terrorism, or to deal with property that terrorists own or control. An accountant is barred from acting for a client it knows or has reasonable grounds to believe is a terrorist entity, and it must alert the authorities; in daily terms, the duty is discharged by checking the client, its agents and its beneficial owners against the terrorism lists at the start of and throughout an engagement.
The United Nations Act 2001
The Act gives the Minister power to translate United Nations Security Council sanctions into binding domestic law, and it is the basis on which Singapore’s country by country measures rest. An accountant does not apply the Act directly but works from the sanctions regulations issued under it, testing its clients and their beneficial owners against the designated person lists those regulations set out.
The United Nations (Sanctions, Democratic People's Republic of Korea) Regulations 2010
Made under the United Nations Act, these regulations bring the Security Council’s North Korea sanctions into domestic force and reach an accountant directly. Because the Accountants Rules require screening against designations made under the United Nations Act, an accountant must not act for a designated person and must freeze and report a match rather than proceed with the engagement.
The United Nations (Sanctions, Iran) Regulations 2019
The Iran regulations carry the Security Council’s Iran measures into Singapore law and bind an accountant in the same way. Since the screening duty in the Accountants Rules expressly reaches designations under the United Nations Act, an accountant must check its clients and their beneficial owners against these lists at the outset of a scoped engagement and escalate any hit rather than clear it quietly.
Overarching AML Laws and Regulations Applicable to Accountants in Singapore
These instruments cut across the whole regime and give an accountant the practical means to discharge its reporting duty and to recognise terrorism financing when it surfaces in an engagement.
Getting Started with SONAR, for STR Filers (2025)
SONAR is the STRO Online Notices and Reporting platform on which an accountant lodges its suspicious transaction reports electronically. It guides you through the registration, user roles and submission, and it is the channel through which the reporting duty under the CDSA is met. An accounting entity’s compliance staff use it to file without delay and to keep proof of every report.
Form Guide for the STR Form (Version 12 August 2025)
A walkthrough of the present suspicious transaction report form, spelling out what belongs in each field, from the filing firm’s own details to the basis for the suspicion, and calling for a distinct internal reference on every submission. An accountant’s staff must keep it to hand when they need to lodge a clear report on a questionable client or an engagement whose numbers will not reconcile.
Terrorism Financing Indicators
A red flag reference from STRO that groups terrorism financing indicators into due diligence anomalies, unusual fund flows and transactions without economic purpose. For an accountant, it sharpens the ability to spot terrorism financing within a client’s accounts or an advisory engagement and supports the decision to submit a terrorism financing report.
National Risk Assessments Applicable to Accountants in Singapore
Singapore publishes formal assessments of where its money laundering, terrorism financing and proliferation financing risks lie, and the Accountants Rules require an accountant to weigh their findings in their own risk assessment. For this sector, the assessments are measured: the accounting profession is rated moderate.
Money Laundering National Risk Assessment Singapore 2024
The national money laundering assessment rates the accounting sector as moderate. It notes that international typologies flag accountancy as a route for high end laundering, that local cases have been few, and that the exposure is limited because accountants do not usually hold client monies. An accountant should read this measured finding into its sector risk assessment while taking the legitimacy seriously and structuring concerns the assessment identifies.
Terrorism Financing National Risk Assessment 2024
The terrorism financing assessment concentrates on banks, remittance and cross border channels rather than on accountants, but its typologies still bear on the profession. An accountant applies the assessment’s indicators when it screens a client and when it reviews an engagement that lacks a clear economic purpose.
Proliferation Financing National Risk Assessment and Counter PF Strategy 2024
This assessment names sanctions evasion, the abuse of legal persons and dual use trade as the main proliferation channels. An accountant’s exposure to transaction and service risks arises where they become involved in the creation or management of companies, legal persons and legal arrangements.
Environmental Crimes Money Laundering National Risk Assessment (May 2024)
An assessment of the laundering routes for money made from environmental offences, spanning wildlife trafficking through to unlawful logging. An accountant may act as an intermediary to facilitate the placement or layering of funds to launder proceeds generated from environmental crimes.
Money Laundering and Terrorism Financing Risk Assessment of Legal Persons (2024)
This assessment rates companies as carrying a higher residual money laundering risk and describes how they are misused through opaque ownership. It matters to an accountant who forms, administers or advises companies, and it reinforces the duty to look through a corporate client to the natural persons who own or control it.
Money Laundering and Terrorism Financing Risk Assessment of Legal Arrangements (2024)
For accountants dealing with trusts, the assessment highlights the importance of identifying relevant trust parties. Singapore’s framework requires information on the settlor, trustee, beneficiary and protector, where applicable, to be maintained and made available for AML/CFT purposes.
Virtual Assets (Digital Payment Tokens) Risk Assessment (2024)
This assessment gauges Singapore’s exposure to activity in digital payment tokens. Its relevance to an accountant is indirect but rising, since a client dealing in such tokens, or one whose wealth derives from them, calls for closer attention when the accountant assesses risk and establishes the source of funds behind an engagement.
Accounting Sector ML/TF Risk Snapshot
Money laundering: moderate, because accountants do not usually handle client monies, though local cases of misappropriation and self laundering have been noted (ML NRA 2024, chapter 8.7).
Main feature to watch: the veneer of legitimacy an accountant can lend to falsified accounts, and the use of complex structures in advisory work to mask beneficial ownership (ML NRA 2024, chapter 8.7).
Terrorism and proliferation financing: indirect, arising where accounts or structures disguise the raising, movement or procurement of funds, mitigated by screening and scrutiny of purpose (TF NRA 2024; PF NRA 2024).
Controls: ACRA registers and reviews public accountants, and ISCA risk rates and engages its members who perform scoped services (ML NRA 2024, chapter 8.7).
Sector Specific Guidance Applicable to Accountants in Singapore
This is the core of an accountant’s obligations. Because the sector is supervised by ACRA and the profession’s own institute rather than by MAS, its rulebook is not a MAS notice but the Accountants Rules, mirrored by the ISCA pronouncement EP 200. The two crux instruments are covered in full below.
Specific Guidelines for Accountants
These instruments apply to all accountants and shape how an accountant designs its controls.
The Accountants Act 2004
The statute that constitutes the profession. It establishes the registration of public accountants, the Public Accountants Oversight Committee and the Registrar of Public Accountants within ACRA, and it empowers the making of the AML Rules under section 64 and their enforcement through the compliance review regime in Part 5A. Registration under this Act is what brings a public accountant within the Rules and ACRA’s oversight.
The Accountants (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Rules 2023
The Accountants (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Rules 2023 set out the key statutory AML/CFT requirements for accountants within their scope. Made under section 64 of the Accountants Act 2004 and in force from 1 July 2023, and amended with effect from 6 May 2026. They apply to an accounting entity and to an individual practitioner of that entity when the entity prepares for or carries out a defined set of activities.
Those activities are the buying and selling of real estate, the managing of a client’s money, securities or other assets, the management of bank, savings or securities accounts, the organisation of contributions for the creation, operation or management of a company, and the creation, operation or management of legal persons or arrangements together with the buying and selling of business entities.
The Rules open with general duties. An accounting entity must conduct its business to guard against facilitating money laundering and terrorism financing, must exercise due diligence to the same end, and must assist the law enforcement authorities.
An accountant must perform customer due diligence when it establishes a business relationship with a client, when it suspects money laundering or terrorism financing, or when it doubts information it already holds. The extent of the measures is set on a risk sensitive basis. The entity must be able to demonstrate to the Registrar that the extent chosen is appropriate to the risk.
The core of the Rules is identification and verification. An accountant must establish and verify the identity of the client and any agent from reliable and independent sources, recording the prescribed particulars, and where the client is a company, it must record the identities of the directors, and for a partnership the partners and managers. It must then inquire whether a beneficial owner stands behind the client and, where one does, identify and take reasonable measures to verify that person, tracing the natural persons who ultimately own the client, then those with ultimate control, and finally those with executive authority. The client and its beneficial owners must be screened against the relevant money laundering, terrorism financing and sanctions lists, and the results recorded.
The Rules are specific about what an accountant records and when the beneficial ownership inquiry can be eased. For each client and agent, the accountant must capture the prescribed particulars, a full name and any alias, an identification or incorporation number, an address and contact details, a date of birth or incorporation and a nationality or place of incorporation.
The inquiry into beneficial owners may be relaxed where the client is a listed company, a regulated financial institution or a Singapore government entity, unless doubt or suspicion arises, and the basis for that determination must be recorded. Where verification cannot be completed at the outset, an accountant may in narrow circumstances begin the work while managing the risk, provided it completes verification as soon as is reasonably practicable, so that no scoped engagement proceeds on an unverified footing for longer than necessary.
The Rules then scale the work to risk. Simplified due diligence is available only where the accountant has assessed and documented that the risk is low. Enhanced due diligence is required for higher risk clients and arrangements, including a politically exposed person and a client connected to a higher risk country, calling for senior approval, steps to establish the source of wealth and funds and closer, more frequent monitoring.
An accountant may rely on a third party, such as a Singapore financial institution or another regulated professional, for elements of due diligence, but it remains responsible for its own compliance and must obtain the underlying records without delay.
The remaining duties complete the framework. An accountant must conduct ongoing monitoring of every business relationship, with enhanced monitoring for higher risk cases, and must keep its records, including of due diligence and of the transactions in a scoped engagement, for at least five years.
It must maintain written internal policies, procedures and controls, run an audit and compliance function proportionate to its size, and ensure its practitioners are screened and trained. A breach of the Rules is dealt with through the compliance review regime in Part 5A of the Accountants Act, under which the Registrar may act against an entity that falls short.
ISCA Ethics Pronouncement EP 200 (effective 1 July 2023)
Ethics Pronouncement EP 200, issued by the Council of the Institute of Singapore Chartered Accountants, is the profession’s AML/CFT ethics pronouncement. It provides AML/CFT requirements and guidelines for professional accountants in Singapore and is applicable to public accountants and accounting entities regulated by ACRA.
First issued in October 2014 and updated several times, it was revised on 1 June 2023 and took effect on 1 July 2023.
Every ISCA member must comply with it. EP 200 directs members to determine whether the work they do falls within the FATF defined activities, and it channels public accountants and public accounting entities to the requirements in the Accountants Rules 2023, while members in business apply the requirements set out in the pronouncement’s own section. In this way, EP 200 makes sure that every ISCA member applies the core measure.
On the risk-based approach, EP 200 walks a member through assessing the money laundering and terrorism financing risk of its clients, the countries it deals with and the services it offers, and through building policies and controls that match that risk.
It then works through customer due diligence in practical terms: how to identify and verify a client and its agents, how to inquire into and verify the beneficial owner behind a corporate client, and how to treat a client that is itself a company, a partnership or a trust. It explains when simplified measures are acceptable and when enhanced measures, including for a politically exposed person, are required, and it addresses reliance on third parties and the safeguards that reliance demands.
EP 200 is at its most useful on recognising and reporting the wrong. It carries indicators of suspicious transactions tailored to the profession, from a client’s reluctance to reveal who really owns a business to instructions that make no commercial sense or a structure that seems designed only to obscure.
It also explains how a member turns a suspicion into a suspicious transaction report to the Suspicious Transaction Reporting Office without tipping off the client. It covers the records a member must keep, the training its people need, and the internal controls, including an appointed compliance function, that turn the requirements into daily practice.
EP 200 is structured to serve two audiences at once. One part carries the requirements for members in business, who apply them to the extent their work is scoped, while the part for members in public practice points to and incorporates the Accountants Rules 2023, so that a public accountant reads a single, consistent set of obligations. Its appendices give the practical tools, including indicators of suspicious transactions written for the profession, and it is supported by a summary of requirements and a set of frequently asked questions that ISCA maintains for its members.
Because the pronouncement is refreshed as the law changes, a member is expected to work from the current edition and to treat the pronouncement, the summary and the FAQs as a single body of guidance.
EP 200 also sets the professional consequences. Because compliance is mandatory for ISCA members, a breach can trigger the institute’s complaints and disciplinary process, separate from and additional to any action ACRA takes against a public accountant under the Accountants Act.
The pronouncement reminds a member that the duty to report a suspicion attaches to the person who forms it and cannot be contracted away, that ISCA monitors members through an annual declaration and risk rates those who perform scoped services, and that record keeping is the evidence a member relies on if its work is later examined. Read with the Rules, EP 200 turns a set of legal duties into a professional standard the whole membership is held to.
FAQs Anti Money Laundering and Countering the Financing of Terrorism Requirements and Guidelines for Professional Accountants in Singapore
The FAQs on Anti Money Laundering and Countering the Financing of Terrorism Requirements and Guidelines for Professional Accountants in Singapore explain how professional accountants and accounting firms should comply with AML and CFT obligations under ISCA Ethics Pronouncement EP 200. The guidance covers risk assessment, customer due diligence, beneficial ownership identification, enhanced due diligence for higher risk customers and politically exposed persons, ongoing monitoring, suspicious transaction reporting, tipping off, record keeping, internal controls, employee training and independent testing. It also explains the additional requirements that apply when accountants carry out specified activities such as managing client assets, managing accounts, forming or managing companies and trusts, or buying and selling business entities.
AML CFT A Summary of Requirements and Guidelines for Professional Accountants in Singapore
The document provides a practical overview of the AML and CFT requirements that professional accountants and accounting firms in Singapore should follow under EP 200. It covers risk based customer due diligence, identification and verification of customers and beneficial owners, screening for sanctions and politically exposed persons, enhanced due diligence for higher risk clients, ongoing monitoring, suspicious transaction reporting, record keeping, internal controls and appropriate procedures for accepting or continuing client relationships. It also emphasises that firms should tailor their AML and CFT procedures to their risks and remain responsible for ensuring compliance with the applicable requirements.
When the AML Rules Apply to an Accountant
The rules turn on the work, not the title. The table below sets out the five scoped activities in rule 3 that bring an engagement within the regime; outside them the Rules do not apply.
Scoped activity (rule 3) | When an accountant prepares for or carries it out, the AML rules apply |
Buying and selling real estate | Acting for a client on a property purchase or sale, the classic route for placing illicit funds in a high value asset |
Managing money, securities or other assets of client | Handling or directing a client’s money, securities or other assets, where the accountant touches the value being moved |
Managing bank, savings or securities accounts | Operating or administering a client’s accounts, a point at which layered funds can pass through |
Organising contributions to form or run a company | Arranging the capital or contributions for the creation, operation or management of a company |
Forming or managing legal persons or arrangements | Creating, operating or managing companies, partnerships or trusts, and buying or selling business entities |
Who Supervises which Accountant
The profession is supervised on two tracks that meet the same requirements. The table below draws the map.
Who the accountant is | Supervisor and binding AML instrument |
Public accountant or public accounting entity | Registered with and supervised by ACRA under the Accountants Act; bound by the Accountants (PMLFTPF) Rules 2023 when it performs a scoped activity |
Professional accountant who is an ISCA member | Subject to ISCA’s Ethics Pronouncement EP 200, which since 1 July 2023 carries the same AML/CFT requirements as the Rules 2023 |
ISCA member in business, not in public practice | Complies with the AML/CFT requirements in Section 1 of EP 200 to all ISCA members |
An accountant already supervised elsewhere | Accountant providing services regulated under another AML/CFT regime may also have obligations under that regime. The applicable supervisory and professional requirements should be assessed based on the services and regulatory status of the accountant |
Where suspicions go | Accountant knows or has reasonable grounds to suspect that property may be connected to criminal conduct, a suspicious transaction report (STR) must be filed with the Suspicious Transaction Reporting Office (STRO) |
Allied Laws Applicable to Accountants in Singapore
These statutes and instruments are not primarily AML rules, but each supports the regime: some constitute and govern the profession, others govern the legal persons an accountant forms or advises, and others give investigators their powers or create the offences an accountant screen against.
The Accountants (Public Accountants) Rules 2006
The rules governing the registration, qualification, continuing education and practice of public accountants. They set the professional gate a public accountant must pass and keep, and they form the regulatory frame within which the AML Rules and ACRA’s compliance reviews operate.
The Accountants (Prescribed Standards and Code of Professional Conduct and Ethics) Order 2023
The order prescribing the professional and ethical standards that bind public accountants, including the code of conduct. It sits alongside the AML Rules because integrity, objectivity and due care are the professional foundations on which an accountant’s anti money laundering judgement rests.
The Companies Act 1967
The principal statute governing companies, the legal persons an accountant most often audits, forms or advises. Its reforms on beneficial ownership registers and nominee arrangements are the transparency backbone an accountant’s due diligence both relies on and feeds when it looks through a corporate client.
The Limited Liability Partnerships Act 2005
The statute constituting limited liability partnerships, a common form for accounting entities themselves and for clients an accountant serves. It sets the registration, management and disclosure rules for LLPs, and an accountant applies its identification and beneficial ownership duties to the partners and managers behind such a structure.
The Prevention of Corruption Act 1960
Singapore’s principal anti corruption law. Because corruption is a predicate offence for money laundering, the proceeds of offences under it are part of what an accountant watches for when it checks a client’s source of funds, and its presumption on unexplained wealth reinforces scrutiny where a client’s means cannot be explained.
The Criminal Procedure Code 2010
Singapore’s procedural code for criminal matters, granting investigators the authority to compel production and to search and seize. When a production order lands that touches a client or a piece of work, an accountant has to hand over what is asked, keep their records intact and say nothing to the client, and that is the mechanism by which an investigation opens up the working papers.
The Strategic Goods (Control) Act 2002
Governs the transfer and brokering of strategic and dual use goods, the proliferation financing nexus an accountant may encounter in advisory work. Its controls flag exposure where a client’s business, or a structure an accountant advises on, touches trade in such goods.
The Biological Agents and Toxins Act 2005
Regulates the possession, use, importation, transhipment, transfer and transportation of specified biological agents and toxins, including prohibiting their use for non peaceful purposes. It forms part of Singapore’s legal framework for preventing the misuse of biological materials and is relevant to proliferation financing risk where financial activity is connected to prohibited biological weapons activities.
The Chemical Weapons (Prohibition) Act 2000
Implements Singapore’s obligations under the Chemical Weapons Convention by prohibiting activities involving chemical weapons, including their use, development, production, acquisition, stockpiling, retention and transfer. It is relevant to proliferation financing risk because financial transactions can potentially facilitate prohibited chemical weapons activities.
Miscellaneous Laws and Regulations Applicable to Accountants in Singapore
These national strategies, committee reports and typologies set the direction of Singapore’s regime and the public private partnership an accountant operates within. They carry no binding force, but they steer how supervisors act and supply many of the typologies an accountant builds into its checks on clients and structures.
National Anti Money Laundering Strategy 2024
The country’s overarching AML plan is organised around three pillars: Prevent, Detect and Enforce. As a professional gatekeeper, an accountant belongs to the Prevent pillar, the space in which the authorities press for gatekeeper accountability and for the transparency of beneficial ownership that an accountant helps deliver when it sets up or advises a company.
National Strategy for Countering the Financing of Terrorism 2024
Renewed in 2024 alongside the terrorism financing risk assessment, this strategy works on five fronts, joining up how risk is identified, hardening the legal and sanctions framework, keeping supervision robust, pressing enforcement and deepening cooperation. It signals the direction an accountant’s terrorism financing controls and screening should take.
National Asset Recovery Strategy 2024
Singapore’s plan for following, freezing and giving back criminal proceeds, with reference to the amounts recovered of late. An accountant contributes to it chiefly by reporting and by complying with production orders, because the ledgers and structures that pass through its hands may hold assets that end up restrained.
Singapore Law Enforcement Strategy to Combat Money Laundering (October 2024)
A joint strategy of Singapore’s money laundering investigation agencies that sets focus areas and key actions and relies on two way information flows with the private sector. It frames the enforcement backdrop that an accountant supports through its reporting on suspicious clients and engagements.
Inter Ministerial Committee on Anti Money Laundering Report (October 2024)
Commissioned in the aftermath of a major laundering case, this review advanced recommendations on tackling the abuse of corporate structures, tightening what is expected of gatekeepers and improving how information moves between agencies and firms. Its conclusions catch the accounting profession in its gatekeeper role and signal the sterner supervisory posture the professional sector now operates under.
Legal Persons: Misuse Typologies and Best Practices (2018)
A typologies paper on the ways companies and partnerships are misused, giving an accountant the red flags for beneficial ownership and corporate client checks. It is directly useful where an accountant forms, administers or advises a company, a partnership or a trust with an opaque owner.
International Standards Applicable to Accountants in Singapore
Singapore’s regime is built to meet the FATF standards, and the Accountants Rules track them, including the standard that designates accountants as a profession subject to AML obligations when they perform certain activities. These instruments are the least sector specific of all, yet they are the source of the domestic rules, and of the typologies an accountant is expected to keep abreast of.
The FATF Recommendations (updated June 2026)
The 40 Recommendations are the global AML/CFT and counter proliferation standard, and Recommendations 22 and 23 designate accountants as a profession that must apply customer due diligence and report suspicions when they carry out defined activities, which is the origin of the scope test in the domestic Rules.
Methodology for Assessing Technical Compliance and Effectiveness (updated June 2026)
The FATF’s instrument for measuring both technical compliance with the Recommendations and the real world effectiveness of a country’s defences. It fixes the standard against which Singapore, and with it the accounting profession, is assessed, and it feeds directly into what supervisors expect of the sector.
Mutual Evaluation Report of Singapore (May 2026)
The 2026 review by the FATF and the Asia/Pacific Group judges how effectively Singapore’s regime works in practice, with the supervision of designated professions a recurring theme. It frames the expectations ACRA and ISCA carry into their oversight of accountants.
FATF Guidance on Politically Exposed Persons (Recommendations 12 and 22, 2013)
Sets out how to recognise a politically exposed person and step up due diligence, accordingly, obtaining senior sign off, working out the source of wealth and funds, and monitoring the relationship more closely, all of which an accountant brings to bear where a PEP sits behind the client it is engaged by.
Guidance on Beneficial Ownership of Legal Persons (March 2023)
Guidance issued under the revised Recommendation 24 on how to obtain and verify beneficial ownership information, shaping how an accountant pins down the natural person who really owns or controls a corporate client it audits, forms or advises.
Best Practices on Beneficial Ownership for Legal Persons (October 2019)
A collection of country best practices for keeping beneficial ownership information adequate, accurate and up to date, backing an accountant’s use of registries and multiple independent sources when it identifies the owner behind a corporate client.
Concealment of Beneficial Ownership (July 2018)
A FATF and Egmont Group typologies study cataloguing the devices, nominees, intermediaries and stacked structures that criminals use to bury who really owns an asset. It bears closely on an accountant, since the same advisory techniques that structure a group can, in the wrong hands, be turned into the very concealment the report warns of.
Risk Based Approach: Beneficial Ownership and Transparency of Legal Arrangements (March 2024)
Guidance focused on Recommendation 25 and trusts and similar arrangements, helping an accountant assess and mitigate risk where a trust or similar structure stands behind a client it forms, administers or advises.
FATF Guidance on Counter Proliferation Financing (February 2018)
Guidance on carrying out the financial provisions of Security Council resolutions against weapons of mass destruction proliferation, under which an accountant must screen and act without delay in line with Recommendation 7 where a client’s structure could disguise procurement.
Guidance on Proliferation Financing Risk Assessment and Mitigation (June 2021)
Describes how a firm should assess and reduce proliferation financing risk once the changes to Recommendations 1 and 2 brought it within the risk assessment duty, a duty an accountant now discharges as part of its enterprise risk assessment.
Trade Based Money Laundering: Trends and Developments (December 2020)
A FATF study of how criminals launder money by misrepresenting the price, quantity or quality of traded goods. It is pertinent to an accountant whose review of a client’s accounts or invoices may reveal the mispricing and false documentation that mark trade based laundering.
Money Laundering from Environmental Crime (July 2021)
A FATF examination of the ways money generated by environmental crime is channelled through the financial system. It reaches an accountant where the books it examines, or an arrangement it has helped design, end up holding or masking those proceeds behind a respectable front.
Guidance on Digital Identity (March 2020)
Helps an accountant judge whether a digital identity system is reliable and independent enough for customer due diligence under a risk based approach, a live question as firms onboard clients remotely.
Artificial Intelligence and Deepfakes: Impacts on ML/TF/PF
A forward looking FATF scan of how artificial intelligence and deepfakes threaten preventive systems, for example, synthetic identities defeating verification, alongside the uses of such tools in screening and analysis that an accountant can turn to advantage.
Summary of the Key Instruments
The table below distils the instruments an accountant relies on most, what type each is, whom it binds, and the core obligation it places on the professional. Treat it as a fast reference alongside the discussion; the detailed sections above are the controlling text.
Instrument | Type | Binds | Core obligation for an accountant |
CDSA 1992 | Statute | Everyone | Report suspected criminal proceeds; do not tip off |
TSOFA 2002 | Statute | Everyone | Do not deal in terrorist property; screen and report |
UN Act sanctions regulations (DPRK, Iran) | Regulations | All persons | Screen for and act against designated persons |
Accountants (PMLFTPF) Rules 2023 | Rules (binding) | Accounting entities | Scoped-activity CDD, beneficial ownership, records, STR |
ISCA EP 200 (2023) | Professional pronouncement | ISCA members | Same AML/CFT requirements; mandatory for members |
Accountants Act 2004 | Statute | Public accountants | Register and supervise; empower the AML Rules |
FATF Recommendations | Standard | Countries/professions | Designate accountants; global CDD standard |
Conclusion
For an accountant in Singapore, the anti money laundering framework turns on the work rather than the title, and where the work is in scope it is enforced by the profession’s own supervisors. The criminal statutes make laundering and terrorism financing offences and require suspicions to be reported; the sanctions regulations require designated parties to be screened out; and the Accountants Rules, mirrored by EP 200, turn all of this into a working system of scoping, risk assessment, customer due diligence, beneficial ownership tracing, enhanced measures for higher risk cases and suspicious transaction reporting. Because the risk lies in legitimacy and structure rather than in the handling of cash, an accountant’s controls are built around who its client really is and whether an engagement makes commercial sense.
The instruments interlock. An accountant’s risk assessment draws on the national risk assessments; its due diligence flows from the Accountants Rules and EP 200; its registration and professional standing come from the Accountants Act and the profession’s own rules; and its beneficial ownership work is anchored in the Companies Act reforms and the FATF standards. Seeing how the pieces connect, and remembering that ACRA and ISCA, not MAS, are the supervisors, is what turns a scope based obligation into a framework an accountant can defend.
An accountant that also provides corporate services comes under the ACRA corporate service provider regime as well, covered in our companion guides to corporate service providers and to accountants, lawyers and law practices providing CSP services.
Frequently Asked Questions
Public accountants and accounting entities are subject to ACRA’s AML/CFT requirements under the Accountants Act 2004 and the Accountants (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Rules 2023. ISCA members are also required to comply with ISCA’s Ethics Pronouncement EP 200.
The ACRA Rules 2023 apply in full when a professional accountant in public practice or professional firm prepares for or carries out a specified high risk activity, including buying or selling real estate, managing client money, securities or other assets, managing bank, savings or securities accounts, organising contributions for the creation or management of companies, and creating, operating or managing legal persons or arrangements or buying and selling business entities. For other activities, AML/CFT requirements continue to apply on a risk sensitive basis.
Singapore’s 2024 assessment rates the sector as moderate. Accountants do not usually handle client monies, which limits their exposure, but they can lend a veneer of legitimacy to falsified accounts or use complex structures in advisory work to obscure beneficial ownership, and there have been local cases of accountants misappropriating and self laundering funds.
EP 200 is ISCA’s Ethics Pronouncement on AML/CFT requirements and guidelines for professional accountants in Singapore. Revised on 1 June 2023 and effective from 1 July 2023, it adopted the AML/CFT requirements contained in the ACRA Accountants Rules 2023. All ISCA members are required to comply with EP 200, while professional accountants in public practice and professional firms are also subject to the ACRA Rules where applicable.
The accountant must inquire whether a beneficial owner exists and identify and verify the beneficial owner using reliable and independent sources. For a legal person, this involves identifying the natural persons who ultimately own or control the client and, where no such person can be identified, the relevant natural person exercising executive control.
An accountant must file a suspicious transaction report with the Suspicious Transaction Reporting Office (STRO) where, in the course of the accountant’s business or profession, the accountant knows or has reasonable grounds to suspect that any property may be connected to criminal conduct. The accountant must also comply with the applicable prohibition on tipping off. Our guide to STR red flags explains common triggers, such as instructions that make no commercial sense or a structure that seems designed only to obscure ownership.
About the Author
Pathik Shah
FCA, CAMS, CISA, CS, DISA (ICAI), FAFP (ICAI)
Pathik is a Chartered Accountant with more than 26 years of experience in governance, risk, and compliance. He helps companies with end-to-end AML compliance services, from conducting Enterprise- Wide Risk Assessments to implementing the robust AML Compliance framework. He has played a pivotal role as a functional expert in developing and implementing RegTech solutions for streamlined compliance.
