AML Laws and Regulations in Singapore: The Complete Guide

Table of Contents

In a Nutshell

The base layer binds everyone. The Corruption, Drug Trafficking and Other Serious Crimes Act 1992, the Terrorism (Suppression of Financing) Act 2002 and the sanctions regulations made under the United Nations Act 2001 apply to every person and business in Singapore, whatever their sector.

Each sector has its own rulebook and supervisor. Financial institutions are subject to MAS Notices. Designated non-financial businesses and professions are subject to sector-specific requirements under the laws and guidelines applicable to their activities, with supervision carried out by the relevant authority, including ACRA, the Gambling Regulatory Authority, the Council for Estate Agencies, the Controller of Housing and the Ministry of Law.

The duties rhyme across sectors. A risk-based approach, customer due diligence, beneficial ownership tracing, sanctions screening, ongoing monitoring, suspicious transaction reporting and record keeping recur in every rulebook, tuned to each sector’s risk.

All reports flow to one place. Suspicious transaction reports, and cash transaction reports where required, go to the Suspicious Transaction Reporting Office through the SONAR platform.

This guide links to 25 sector guides. Sixteen financial institution sectors and nine DNFBP sectors, each with its own detailed guide to the exact instruments that bind it.

AML Laws and Regulations in Singapore: Guide

Singapore is a major global financial and trading hub, and the scale and international reach of its economy expose it to significant money laundering, terrorism financing and proliferation financing risks.  In response, Singapore has established a comprehensive AML, CFT and CPF framework that combines criminal and targeted financial sanctions laws with sector specific regulatory requirements and supervision by specialised authorities. National risk assessments and sectoral risk assessments help identify emerging threats and guide the application of risk-based controls across the financial and non-financial sectors.

The framework is best understood as a set of interconnected layers. International standards and National risk assessments inform the development of Singapore’s laws and regulatory approach. Criminal statutes establish money laundering and related offences, while targeted financial sanctions measures require identifying designated persons and entities and, where applicable, freezing their assets or funds. Sector specific laws, regulations, notices and guidelines then translate these requirements into day-to-day obligations, while individual firms implement them through their own policies, procedures and controls.

What Money Laundering, Terrorism Financing and Proliferation Financing Mean?

Money laundering is the process of making the proceeds of crime appear legitimate. It is usually described in three stages: placement, where illicit funds first enter the financial system; layering, where the trail is obscured through transfers, companies and cross-border movement; and integration, where the funds return to the criminal as apparently legitimate wealth. Terrorist financing is the raising, providing or moving of funds to support terrorism, whether the money comes from legitimate or criminal sources, while proliferation financing concerns the provision of funds or financial services connected with the proliferation of weapons of mass destruction and their delivery systems, including through sanctions evasion.

Singapore’s regime is designed to address each of these risks. The controls a regulated business runs, from identifying a customer at placement to monitoring transactions and reporting suspicious activity, exist because criminals can misuse the financial system at different points, and different sectors may be exposed to different types and stages of these risks.

Core criminal and sanctions laws

These instruments form the base and apply to every business, regulated or not. The Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 (CDSA) establishes money laundering as an offence, provides the power to confiscate criminal proceeds, the duty to file a suspicious transaction report and the offence of tipping off. The Terrorism (Suppression of Financing) Act 2002 criminalises dealing in terrorist property. The United Nations Act 2001 provides the legal basis for giving effect to certain United Nations Security Council measures in Singapore. Regulations made under the UN Act then impose targeted financial sanctions obligations on specified persons and sectors, including requirements to screen for designated persons and freeze funds or assets without delay where applicable.

The FATF standards and Singapore's place in them

Singapore is a member of the Financial Action Task Force and of the Asia/Pacific Group on Money Laundering, and its regime is designed to meet the FATF 40 Recommendations, the global standard for AML, CFT and CPF. The FATF assesses each member by mutual evaluation, judging both technical compliance and how well the system works in practice. Nearly every duty in a Singapore sector rulebook, from the risk-based approach to beneficial ownership identification to reporting, traces back to a FATF Recommendation, which is why the same obligations recur across otherwise different sectors.

National risk assessments

Singapore publishes formal assessments of where its money laundering, terrorism financing and proliferation financing risks lie, and every regulated business must feed its findings into its own risk assessment. The core money laundering and terrorism financing national risk assessments are supported by dedicated assessments of proliferation financing, of legal persons and legal arrangements, of environmental crimes and of virtual assets. The 2024 assessment is the current reference point, and it is candid about which sectors carry the most risk.

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Who Must Comply

Singapore’s AML/CFT obligations fall on two broad groups. Financial institutions, which MAS licenses and supervises, are caught by virtue of their licence or registration. The designated non-financial businesses and professions, the DNFBPs, are caught when they carry out defined gatekeeper activities, such as forming companies, dealing in property, handling client money or selling high value goods. A business can sit in both worlds at once; for example, an accounting firm that also provides corporate services, and where it does, it must satisfy each regime for the relevant work.

Group

Who is covered and how

Financial institutions

Banks, merchant banks, finance companies, capital markets intermediaries, insurers, trust companies, financial advisers, payment and digital payment token services and more, caught by their MAS licence or registration

DNFBPs

Corporate service providers, accountants, lawyers, casinos, pawnbrokers, precious stones and metals dealers, and real estate agencies and developers, caught when they perform defined activities

Dual-hatted firms

A firm that does more than one kind of regulated work, such as an accountant or lawyer that also provides corporate services, must meet each applicable regime

Singapore's AML/CFT/CPF Supervisors

Singapore does not have a single AML regulator. Instead, supervision is divided by sector, with businesses generally subject to the authority responsible for licensing or regulating their activities.  The Monetary Authority of Singapore (MAS) supervises financial institutions, while DNFBPs are overseen by their respective competent authorities, including ACRA, the Institute of Singapore Chartered Accountants, the Gambling Regulatory Authority, the Council for Estate Agencies, the Controller of Housing within the Urban Redevelopment Authority, and the Ministry of Law and its registries. Above them all sits Singapore’s financial intelligence unit, i.e., the Suspicious Transaction Reporting Office, which receives and analyses the reports the reporting entities submit.

Supervisor

Sectors it supervises for AML/CFT

Monetary Authority of Singapore (MAS)

All financial institutions: banks, merchant banks, finance companies, capital markets services licensees, insurers, trust companies, financial advisers, payment and digital payment token service providers, the securities depository, VCCs and more

ACRA

Corporate service providers and public accountants (and accounting entities and law practices that provide corporate services)

Institute of Singapore Chartered Accountants

Professional accountants who are ISCA members, through Ethics Pronouncement EP 200

Gambling Regulatory Authority

The casino operators

Council for Estate Agencies

Real estate agencies and salespersons

Controller of Housing (within URA)

Licensed housing and commercial property developers

Ministry of Law

Money lenders (Registrar of Moneylenders), pawnbrokers (Registrar of Pawnbrokers), and precious stones and metals dealers (AML/CFT Division)

Law Society of Singapore and Ministry of Law

Legal practitioners and law practices

Suspicious Transaction Reporting Office (STRO)

The financial intelligence unit that receives all suspicious and cash transaction reports

The AML/CFT/CPF Obligations Every Regulated Business Shares

However different the sectors look, their rulebooks ask for the same core measures, scaled to risk. A business assesses its own risk, then knows its customer, watches the relationship, and reports what does not add up.

Obligation

What it means in practice

Risk-based approach

Assess and document the ML, TF and PF risk across customers, countries, products and channels, and match the depth of controls to the risk

Customer due diligence

Identify and verify the customer, any person acting for them, and the beneficial owner behind a company or trust, using reliable and independent sources

Sanctions and PEP screening

Screen customers and beneficial owners against the United Nations Act and terrorism designations, and identify politically exposed persons

Enhanced and simplified measures

Apply enhanced due diligence to high-risk cases, including source of wealth and senior management approval, and simplified measures only where risk is demonstrably low

Ongoing monitoring

Keep due diligence current and watch transactions for activity that does not fit the customer’s profile

Suspicious transaction reporting

Report to STRO on reasonable grounds to suspect ML or TF, without tipping off the customer; file cash transaction reports where the sector requires them

Records, audit and training

Keep records for the prescribed period, run an independent audit function, appoint a compliance officer and train staff

Our concept guides explain the recurring building blocks in depth: when customer due diligence is required, how enhanced due diligence works, the difference between source of funds and source of wealth, how to treat a politically exposed person, and the red flags that trigger a suspicious transaction report.

The AML Rulebook For Each Sector

This is the heart of the guide. Each sector below has its own detailed guide to the exact laws, notices, rules and guidelines that bind it, the supervisor that enforces them, and the crux instrument at its centre. Start with the base laws above, then read the guide for your sector.

Financial Institutions

MAS supervises financial institutions, and their binding instrument is almost always a MAS Notice, backed by the MAS AML/CFT/CPF Guidelines. There are sixteen sector guides.

Sector guide

Supervisor

Primary crux instrument

Banks

MAS

MAS Notice 626

Merchant Banks

MAS

MAS Notice 1014

Finance Companies

MAS

MAS Notice 824

Capital Market Service Providers

MAS

MAS Notice SFA 04-N02

External Asset Managers

MAS

MAS Notice SFA 04-N02

Fund Management Companies

MAS

MAS Notice SFA 04-N02

Direct Life and Composite Insurers

MAS

MAS Notice 314

Financial Advisers

MAS

MAS Notice FAA-N06

Licensed Trust Companies

MAS

MAS Notice TCA-N03

Payment Service Providers

MAS

MAS Notice PSN01

Digital Payment Token Service Providers

MAS

MAS Notice PSN02

Non-Bank Credit Card Issuers

MAS

MAS Notice 626A

Securities Depository

MAS

MAS Notice SFA 03AA-N01

Variable Capital Companies

MAS

MAS Notice VCC-N01

Approved Trustees for Collective Investment Schemes

MAS

MAS Notice on AML/CFT

Money Lenders

Registrar of Moneylenders (MinLaw)

Moneylenders (PMLTFPF) Rules 2009

Designated non-financial businesses and professions

The DNFBP sectors are the gatekeepers to company formation, property, high value goods and professional services. Each answers to its own supervisor under its own rulebook, and there are nine sector guides.

Sector guide

Supervisor

Primary crux instrument

Corporate Service Providers

ACRA

CSP Regulations 2025

Accountants

 ISCA

Accountants (PMLFT) Rules 2023; EP 200

Accountants, Lawyers and Law Practices providing CSP services

ACRA

CSP Regulations 2025 (deemed registration)

Legal Professionals

Law Society / MinLaw

Legal Profession (PMLFT/PF) Rules 2015

Casinos

Gambling Regulatory Authority

Casino Control (PMLTFPF) Regulations 2009

Pawnbrokers

Registrar of Pawnbrokers (MinLaw)

Pawnbrokers Act 2015 (AML Part)

Precious Stones and Precious Metals Dealers

CFT Division under MinLaw AML

PSPM Act 2019

Real Estate Agencies and Salespersons

Council for Estate Agencies

Estate Agents (PMLPFTF) Regulations 2021

Real Estate Developers

Controller of Housing (URA)

Housing Developers (PMLPFTF) Rules 2023

Penalties and Enforcement

The regime is enforced, and the consequences are both criminal and regulatory. Under the CDSA, the money laundering offences carry heavy fines and imprisonment, and failing to file a suspicious transaction report or tipping off a customer is itself an offence. Each sector statute adds its own penalties: carrying on a regulated business without registration, failing to perform due diligence, or failing to file the reports the sector requires can bring fines, suspension or the loss of a licence.

Enforcement has sharpened. Singapore’s largest money laundering case, uncovered in 2023, led to the seizure of assets worth billions of dollars and a wide-ranging Inter-Ministerial Committee review in 2024 whose recommendations on corporate structures, gatekeepers and information sharing are now working through the sector rulebooks, including the 2025 tightening of the developer and corporate service regimes. Regulated businesses across every sector now sit under closer supervision than a few years ago.

Conclusion

Singapore’s anti-money laundering regime is broad, layered and specific. The criminal and sanction laws bind everyone; the FATF standards explain why the rules look the way they do; the national risk assessments say where the risk is; and each sector has a rulebook and a supervisor of its own. For a regulated business, compliance means reading all these together: knowing the base laws, knowing your sector’s crux instrument, and building controls that a supervisor can test. Use the base laws set out above as your foundation, then follow the guide for your sector for the detail that applies to you.

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Frequently Asked Questions

The base laws that bind every business are the Corruption, Drug Trafficking and Other Serious Crimes Act 1992 (the CDSA), the Terrorism (Suppression of Financing) Act 2002, and the sanctions regulations made under the United Nations Act 2001. On top of these, each regulated sector has its own rulebook, such as the MAS Notices for financial institutions and the Corporate Service Providers Regulations 2025, the Estate Agents Regulations 2021 and the Casino Control Regulations 2009 for various DNFBP sectors.

There is no single AML regulator. MAS supervises financial institutions; ACRA supervises corporate service providers and public accountants; the Gambling Regulatory Authority supervises casinos; the Council for Estate Agencies supervises estate agencies; the Controller of Housing supervises developers; and the Ministry of Law supervises moneylenders, pawnbrokers and precious stones and metals dealers. The Suspicious Transaction Reporting Office receives all reports.

All financial institutions licensed or registered by MAS, and the designated non-financial businesses and professions (DNFBPs) when they carry out defined gatekeeper activities. The DNFBP sectors are corporate service providers, accountants, lawyers, casinos, pawnbrokers, precious stones and metals dealers, and real estate agencies and developers.

The Suspicious Transaction Reporting Office is Singapore’s financial intelligence unit, within the Commercial Affairs Department of the Police. A suspicious transaction report is a filing a business must submit to STRO, through the SONAR platform, whenever it has reasonable grounds to suspect money laundering or terrorism financing. Some sectors, such as casinos, pawnbrokers and precious stones and metals dealers, must also file cash transaction reports above a threshold.

A risk-based approach, customer due diligence including beneficial ownership identification and verification, sanctions and politically exposed persons screening, enhanced measures for high-risk cases, ongoing monitoring, suspicious transaction reporting, record-keeping, audit and training. The detail differs by sector, but these building blocks recur in every rulebook.

They are both criminal and regulatory. The CDSA money laundering offences carry substantial fines and imprisonment, and failing to report a suspicion or tipping off a customer is an offence. Each sector statute adds penalties for carrying on business without registration, failing to perform due diligence or failing to report, ranging from fines to suspension or loss of licence.

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.