AML Laws and Regulations for Financial Advisers in Singapore
In a Nutshell
A financial adviser is a licensed corporate entity or an individual regulated under the Financial Advisers Act 2001, a registered insurance broker, or a person exempted under the Financial Advisers Regulations, whose business includes advising on investment products and arranging life policies. However, a person whose business is limited to issuing research reports is outside the AML, CFT and CPF notice.
The sector’s specific framework is MAS Notice FAA N06 and its Guidelines. They establish the risk-based approach and requirements for customer due diligence, beneficial ownership, enhanced measures for politically exposed persons, reliance on third parties, record keeping and suspicious transaction reporting.
Financial Advisers are important gatekeeper at the point where clients enter the financial system, even though they are not typically the institutions moving or holding client assets. Singapore’s 2024 assessment places financial advisers in the low money laundering risk band, but they are still expected to apply effective controls and act as a first line of defence when onboarding and servicing clients.
Around this core sit Singapore’s criminal and sanctions legislations, the national risk assessments, the Financial Advisers Act that licenses the sector, and the FATF standards. This guide works through each instrument in plain language, explains why it matter to financial advisers, and links each requirement to its underlying source.
AML Laws and Regulations for Financial Advisers in Singapore
Financial advisers sit at the start of many customers’ financial journeys, recommending investment products and arranging life policies, and although they rarely handle client money, they are the first to see who the customer is. This guide sets out the laws and regulations that apply to financial advisers in Singapore, from the criminal statutes that make money laundering an offence to the detailed rulebook the Monetary Authority of Singapore (MAS) enforces on financial advisory firms.
The framework is best understood in layers. At its foundation are the criminal, terrorism financing, and targeted financial sanctions laws that establish the offences and prohibitions that advisers must guard against. Above these sits the sector’s principal AML, CFT and CPF rulebook: MAS Notice FAA N06 and its Guidelines, which set the practical requirements for risk assessment, customer due diligence, and beneficial ownership. Enhanced measures for politically exposed persons, reliance on third parties, record-keeping, and suspicious transaction reporting. Alongside these are the Financial Advisers Act 2001, Singapore’s national risk assessments and FATF standards.
Because financial advisers advise and arrange rather than typically hold or transfer funds, their key AML, CFT and CPF risk lies at the gatekeeping stage: knowing the customer, identifying beneficial owners, assessing risk and preventing financial products from being used to conceal or move illicit wealth. This guide explains each instrument through that practical lens.
Singapore's financial advisers at a glance
As at end 2023 there were over 60 licensed financial advisers in Singapore, alongside registered insurance brokers and exempt advisers, in a sector that has grown steadily in revenue (Money Laundering National Risk Assessment 2024, chapter 7.18).
Financial advisers provide advisory services on capital markets products and life insurance policies; they do not typically handle customer funds or make investment decisions for customers (ML NRA 2024, chapter 7.18).
Risk rating: the sector is assessed in the lowest money laundering risk band, given its retail client base and limited exposure to higher-risk customers, though advisers remain important gatekeepers and first line of defence (ML NRA 2024, chapters 7.1 and 7.18).
Core AML Laws and Regulations in Singapore
These statutes and sanctions regulations make money laundering, terrorism financing and proliferation financing offences and require every financial adviser to detect and report them.
The Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992
The CDSA sets out the money laundering offences in Singapore and lets the courts confiscate criminal proceeds. For financial advisers, the operative duty is section 45: once it knows or suspects that a customer’s funds are proceeds of crime, it must report to the Suspicious Transaction Reporting Office, even though the money itself is usually held by a product provider. Section 57 makes tipping off the customer an offence, which matters in a close advisory relationship.
The Terrorism (Suppression of Financing) Act 2002
The TSOFA makes it an offence to provide or collect property for terrorism and to deal in terrorist property. A financial adviser must decline to act for, or arrange a product for, anyone it knows or has reasonable grounds to believe is a terrorist or under a terrorist’s control, and it must tell the authorities. For advisers, that duty comes down to screening customers and beneficial owners against sanctions and watchlists at onboarding.
The United Nations Act 2001
This Act empowers the Minister to make the regulations that carry United Nations Security Council sanctions into domestic law, and it stands behind Singapore’s country measures. For financial advisers, those measures arrive through MAS regulations, not this Act directly, since the Act gives way where a financial institution is already bound by MAS directions or regulations. The adviser therefore looks to the MAS sanctions regime.
The Financial Services and Markets (Sanctions and Freezing of Assets of Persons, Democratic People's Republic of Korea) Regulations 2023
Made by MAS under the Financial Services and Markets Act 2022, these regulations bring United Nations sanctions on North Korea into force and bind every financial institution, so financial advisers are covered. The advisers must not act for a designated person, must freeze any assets they control, and must report to MAS, with liability that does not depend on having known the customer was designated.
The Financial Services and Markets (Sanctions and Freezing of Assets of Persons, Iran) Regulations 2023
Made by MAS under the FSM Act 2022, the Iran regulations implement Security Council Resolution 2231. Financial advisers must not advise or arrange for designated persons, or in aid of proliferation financing activity, save for narrow exemptions that hinge on a MAS determination. Day-to-day, this means running customers and their beneficial owners against the sanctions lists.
Overarching AML Laws and Regulations Applicable to Financial Advisers in Singapore
These instruments cut across the whole regime and give a financial adviser the practical means to discharge its reporting duties and to recognise terrorism financing when it surfaces in an advisory relationship.
Getting Started with SONAR, for STR Filers (2025)
SONAR is the STRO Online Notices and Reporting platform through which financial advisers lodge their suspicious transaction reports electronically. The guide covers registration, user roles and submission, and it is the practical route by which the section 45 CDSA duty is met. A smaller advisory firm relies on it to file promptly and to keep proof of every filing.
Form Guide for the STR Form (Version 12 August 2025)
A procedural guide to the current suspicious transaction report form. It explains how each part is completed, from the reporting firm’s particulars to the grounds for suspicion, and it asks for a unique internal reference on every filing. For financial advisers, it is the reference a compliance officer uses to file a clear, complete report.
Terrorism Financing Indicators
An STRO red-flag reference that groups terrorism financing indicators into due diligence anomalies, unusual movement of funds and transactions without economic purpose. For financial advisers, it helps surface terrorism financing typologies at onboarding and review, such as a customer whose stated purpose does not match the product sought and supports the decision to file a terrorism financing report.
National Risk Assessments Applicable to Financial Advisers in Singapore
Singapore publishes formal assessments of where its money laundering, terrorism financing and proliferation financing risks lie, and MAS Notice FAA N06 requires advisers to feed their findings into its own risk assessment. For this sector, the assessments are reassuring but not dismissive: financial advisers are rated low risk, yet they remain a gatekeeper.
Money Laundering National Risk Assessment Singapore 2024
The national money laundering assessment places financial advisers in the lowest risk band, because they deal largely with retail investors, do not hold customer funds and have limited exposure to higher-risk customers. It notes the sector’s gatekeeper role and the risk that a large book of accounts, including foreign customers, can make monitoring harder. An adviser should read these findings into its sector risk assessment.
Terrorism Financing National Risk Assessment 2024
The terrorism financing assessment concentrates on banks, remittance and payment channels rather than on advisory firms, but financial advisers are not exempt. They must apply the assessment’s typologies, especially the misuse of legal persons and small cross-border links, when they screen customers and review the purpose behind a product application.
Proliferation Financing National Risk Assessment and Counter PF Strategy 2024
This assessment identifies sanctions evasion, the misuse of legal persons and dual-use trade as the main proliferation channels. For financial advisers, the exposure is largely indirect, arising through corporate customers with opaque structures, so beneficial ownership work and sanctions screening at onboarding shoulder the counter-proliferation load.
Environmental Crimes Money Laundering National Risk Assessment (May 2024)
A thematic look at how the proceeds of environmental crime, from illegal wildlife trade to illegal logging, get laundered. It puts banks and remittance agents in the high-risk sectors, and its relevance to financial advisers is limited, surfacing only where a corporate customer’s wealth may come from such activity.
Money Laundering and Terrorism Financing Risk Assessment of Legal Persons (2024)
This assessment rates companies as high risk for misuse and shows them behind a disproportionate share of suspicious transaction reports. It matters to financial advisers whose customers include corporate vehicles and holding structures, and it reinforces the need to look through to each natural person who owns or controls it.
Virtual Assets (Digital Payment Tokens) Risk Assessment (2024)
This assessment surveys Singapore’s exposure to virtual assets. It has narrow relevance for a financial adviser, which does not deal in digital payment tokens, but it sharpens the attention an adviser pays to a customer whose source of wealth is tied to token activity.
Financial adviser sector ML/TF risk snapshot
Money laundering: lowest risk band, because advisers do not hold customer funds or make investment decisions and largely serve retail clients (ML NRA 2024, chapters 7.1 and 7.18).
Gatekeeper role: as the first point of contact, an adviser is an important first line of defence, expected to identify the customer well even where a product provider does the rest.
Watch areas: a large book with foreign customers can make monitoring harder, and there have been advisers who misrepresented products to customers (ML NRA 2024, chapter 7.18).
Proliferation and terrorism financing: mostly indirect, through corporate customers with opaque ownership (PF and TF NRAs 2024).
Sector-Specific Guidance Applicable to Financial Advisers in Singapore
This is the core of a financial adviser’s obligations. MAS supervises financial advisers and issues the notices and guidance they must follow. The material is divided into common instruments that apply across financial institutions and the specific instruments written for the sector, led by MAS Notice FAA N06 and its Guidelines.
Common Guidelines for Financial Advisers
These MAS instruments apply across financial institutions and shape how a financial adviser designs its controls. They do not replace Notice FAA N06; they explain MAS’s supervisory expectations on themes such as source of wealth, transaction monitoring, misuse of legal persons, sanctions and audit.
The Financial Services and Markets Act 2022
The FSM Act 2022 is the statute through which MAS supervises and enforces AML/CFT across the financial sector, and it supplies the section 16 power under which Notice FAA N06 is issued. It authorises the sanctions regulations an adviser screens against and hands MAS its inspection and direction powers. Since an AML/CFT breach can attract a penalty of up to SGD 1 million, the Act is where the enforcement bite behind the notice comes from.
Circular AMLD 01/2018: Use of MyInfo and CDD for Non Face to Face Business Relations
MAS accepts the Government’s MyInfo service as a reliable and independent source of a customer’s core identity data. Where a financial adviser onboards a MyInfo user, often through an app or portal, it can verify from that data instead of re-gathering documents, so long as it applies the circular’s safeguards for the impersonation risk that arises when MyInfo is not used.
Circular AMLD 01/2022: Non Face to Face Customer Due Diligence Measures
This circular sets MAS’s expectations for onboarding people and entities remotely, which includes advisers meeting customers through a digital platform. It cautions that a video or selfie check on its own may fall short, suggests a second, independent channel for high-risk customers, and expects any onboarding technology to be assessed by the firm and approved by its board and senior management.
Circular AMLD 02/2023: ML/TF Risks in the Wealth Management Sector
Although aimed at wealth management, this circular reaches financial advisers serving affluent customers or advising on wealth products. It calls for firmer board oversight, review of due diligence and quality assurance, and for looking through trusts and holding vehicles to the real beneficial owners, and it treats a customer who withdraws rather than answering questions as a reason to consider a report.
Circular AMLD 08/2024: Establishing the Sources of Wealth of Customers
This circular explains how a firm should establish a customer’s source of wealth before business begins. For advisers, it matters most when a higher net-worth customer seeks a large investment product: the adviser should take reasonable steps to establish the source of wealth, corroborate it under the tests of materiality, prudence and relevance, and escalate what it cannot stand up.
Circular AMLD 05/2026: Risk Proportionate Source of Wealth Establishment
A 2026 circular calibrating the source of wealth expectations. MAS asks that the work stay effective, efficient and proportionate, so ordinary retail customers are not put through unnecessary hoops. Financial advisers should concentrate corroboration on material or higher-risk wealth, avoid repeated requests for low-risk customers, and keep escalation for real red flags.
Circular AMLD 11/2023: Ensuring Effective Detection of Sanctions Related Risks
MAS requires firms to detect and manage sanctions risk, including unilateral sanctions imposed by other jurisdictions. The board must set the risk appetite, and the circular describes a lookback review after a designation. For advisers, the practical effect is disciplined screening of customers and beneficial owners and a review of past relationships when a name is listed.
Circular AMLD 12/2024: Audit of AML/CFT Policies, Procedures and Controls
This circular concerns the independent audit that makes up a firm’s third line of defence. Financial advisers must run an audit function, scaled to their size, that checks whether the AML/CFT controls really work, staff it with suitable expertise, put high-risk areas such as onboarding and reliance first, and measure itself against industry best practice.
Strengthening AML/CFT Controls on Misuse of Legal Persons and Complex Structures (August 2023)
From inspection work, this MAS paper describes firms that let concerning flows run through trusts, foundations and layered corporate structures. Its case studies lay bare Failures to establish the true beneficial owner. Financial advisers onboarding corporate customers should measure themselves against it and be sure they have traced the natural persons behind a structure before advising.
AML/CFT Supervisory Expectations from Recent Inspections (October 2024)
Drawn from recent inspections, this paper groups MAS’s expectations under five headings: treating multiple nationalities and investment migration links as risk factors, catching document red flags, testing whether a customer’s source of wealth holds up, backing a report or an exit with real mitigation, and sharing customer information across business lines. For financial advisers, each one bears on onboarding and periodic review.
Best Practices in Relation to Risks in Wealth Management (May 2025)
An industry paper for firms serving wealthy customers, consolidating case studies on private investment companies, trusts, remote onboarding and investment migration clients. It reaches financial advisers advising affluent customers, and it confirms that where an adviser sits between the customer and a product provider, it must still satisfy its own due diligence duties on that customer.
Effective Practices to Detect and Mitigate the Risk from Misuse of Legal Persons (June 2019)
This MAS paper is about defending against shell and front companies over the life of a relationship. It sets out multi-factor risk assessment, red-flag lists, network link analysis and staff training, and it stresses that a single red flag seldom decides the matter. Financial advisers onboarding corporate customers should weigh several signals together before acting.
Guidance for Effective AML/CFT Transaction Monitoring Controls (September 2018)
MAS collects here its inspection-based expectations for transaction monitoring. An adviser sees far fewer transactions than a bank, so the guidance is applied proportionately, yet its themes, tuning what to look for, keeping data clean and recording how alerts are handled, still shape how an adviser watches customer behaviour and product instructions.
Guidance to Capital Markets Intermediaries on Enhancing AML/CFT Frameworks and Controls (January 2019)
Written for capital markets intermediaries, this MAS guidance on governance, risk awareness and execution binds financial advisers directly only where the same firm also holds a capital markets services licence. For other advisers, it is persuasive good practice on board accountability, the three lines of defence and how a firm resources its AML/CFT programme.
Guidelines on Risk Management Practices, Internal Controls (July 2024)
A prudential guideline setting MAS’s expectations for a firm’s control environment and business process controls. It treats customer due diligence only lightly and leaves the detail to the AML/CFT notices and guidelines, so for advisers it supplies the internal controls framework, from segregation of duties to management information, around which the AML/CFT programme is organised rather than a source of AML duties in itself.
Guidelines on Provision of Digital Advisory Services (October 2018)
he conduct guideline for digital or robo-advisory services, and one that speaks directly to financial advisers that deliver advice online. Its AML/CFT content is brief but pointed: a digital adviser must still have adequate ML, TF, PF controls under the applicable notice and must manage the impersonation risks of a non-face-to-face model, which is the norm for an app-based advisory business.
Sound Practices to Counter Proliferation Financing (August 2018)
From MAS’s thematic reviews, this paper tackles proliferation financing tied to DPRK and Iran sanctions evasion. It explains how firms should raise their controls, monitor high-risk customers and counterparties, and recognise typologies such as shell companies with nominee directors. It matters to advisers whose corporate customers may have links to dual-use trade or higher-risk jurisdictions.
Strengthening Financial Institutions' CFT Controls (May 2023)
This MAS information paper, informed by an industry survey, addresses countering the financing of terrorism. It repeats the duty to freeze and report designated party assets and sets expectations for screening, escalation and prompt, good-quality reporting, each of which a financial adviser brings to its customers and their beneficial owners at onboarding and review.
Specific Guidelines for Financial Advisers
These are the instruments written for the sector. Two of them, MAS Notice FAA N06 and its Guidelines, are the rulebook advisers live by. The remaining notices apply to advisers when, and to the extent that, it carries on the particular activity each one governs.
MAS Notice FAA N06 on Prevention of Money Laundering and Countering the Financing of Terrorism, Financial Advisers
Notice FAA N06 is the binding AML, CFT and CPF rulebook for the sector. Issued under section 16 of the Financial Services and Markets Act 2022, it applies to licensed financial advisers under the Financial Advisers Act 2001, registered insurance brokers exempt under section 20(1)(c) of the FAA, and to persons exempt under regulation 27(1)(d) of the Financial Advisers Regulations. It does not apply to anyone whose business is limited to issuing research analyses or reports. The current version took effect on 1 July 2025, and the Notice treats money laundering as including proliferation financing.
The Notice defines what constitutes a customer and business relationship, which matters because financial advisers provide advice rather than accounts. A business relationship includes opening or maintaining an account or providing financial advice, and where an adviser arranges a group life insurance policy, the owner of the master policy is treated as the customer. The Notice requires advisers to identify, assess and understand their money laundering and terrorism financing risks across customers, countries of operation, products, services and delivery channels, and to apply a risk-based approach with senior-management approved policies, enhanced measures where risk is higher, and risk assessments for new products and technologies before launch.
Customer due diligence is the core. An adviser must not establish or maintain a business relationship with a customer using an anonymous or fictitious name and must perform customer due diligence when it establishes a business relationship, when it suspects money laundering or terrorism financing, or when it doubts the reliability of information it holds. The advisers must identify and verify the customer using reliable independent sources, identify anyone acting on the customer’s behalf and verify their authority, identify relevant connected parties of a legal person, and identify and verify beneficial owners through the prescribed cascade of ownership, control and, where necessary, senior management while understanding the customer’s ownership and control structure.
Simplified due diligence is available only where risk is demonstrably low. Enhanced due diligence is mandatory for politically exposed persons, requiring senior-management approval, establishment of source of wealth and source of funds and enhanced monitoring for other higher-risk situations identified by the advisers. Ongoing monitoring continues throughout the relationship: the adviser must keep due diligence information current and watch for behaviour inconsistent with what it knows about the customer, such as an instruction that makes no commercial sense for the product advised.
The later provisions reflect how advisers work. Reliance is central: an adviser may rely on a qualifying third party, typically a product provider such as an insurer or fund manager, or another eligible financial institution, to perform elements of due diligence, and an acquiring adviser may rely on due diligence already performed when it takes over a book of customers, but in every case the adviser remains responsible for its own obligations.
Records must be kept for at least five years, and the Notice disapplies certain personal data access rights, so controls are not tipped off. Suspicions must be reported to the Suspicious Transaction Reporting Office through a single internal reference point, mindful of the tipping-off offence in section 57 of the CDSA, and the adviser must maintain internal policies, a group policy where it is part of a financial group, an AML/CFT compliance officer, an independent audit function and regular training for its officers and representatives.
Guidelines to MAS Notice FAA-N06 (the primary guidance for financial advisers)
The Guidelines to Notice FAA N06 are the primary guidance financial advisers work with, and it is given the fullest treatment here. It is dated July 2025, and the chapters mirror the paragraphs of the Notice, so advisers can read each obligation next to its explanation. They are guidance and not binding rules, yet MAS makes clear that how far a firm observes them can feed into its overall view of the firm, including how well its board and senior management exercise oversight, so in practice they are the benchmark advisers are measured against.
The Guidelines open with the sector’s risk profile, which is lighter than most. An adviser advises and arranges rather than holding money, so its exposure is concentrated at onboarding, in knowing who the customer is and whether the product fits an honest purpose, rather than in moving funds. The Guidelines confirm that proliferation financing is treated as part of money laundering throughout, and they set out the accountability model: the board and senior management own AML/CFT effectiveness, supported by the three lines of defence, scaled to what is often a smaller firm.
On the risk-based approach, advisers must assess their money laundering and terrorism financing risk not only for individual customers but on an enterprise-wide basis, taking in the products, customer types and the channels through which it advises, and including overseas branches and subsidiaries where it is part of a financial group. The enterprise-wide assessment must be approved by senior management, should combine qualitative and quantitative analysis, must incorporate the findings of Singapore’s national risk assessments, and should be refreshed when a material change occurs, such as a new product line or a new customer segment.
The customer due diligence chapter is the longest, and it is written for a business that identifies customers but does not custody their assets. It explains verification from reliable and independent sources, how to treat a person acting for the customer, connected parties and beneficial owners, and it sets the widely used benchmark that a beneficial owner is generally a natural person who owns more than 25% of an entity, while making clear that anyone who controls the customer through other means is a beneficial owner regardless of any percentage. It works through the group life insurance case, where the master policy owner is the customer, and through non-face-to-face onboarding, which for many advisers is the normal channel, setting out the additional measures that counter impersonation. On timing, verification should generally be completed before or during the establishment of business relations.
The enhanced due diligence chapter defines politically exposed persons in line with the FATF standard, confirms that domestic PEPs include at least Ministers and Members of Parliament, and draws the important distinction between source of wealth and source of funds: source of wealth is the origin of the customer’s entire body of wealth and how it was acquired, while source of funds is the origin of the particular money used. An adviser should corroborate this information against reliable, independent sources, focus on material or higher-risk wealth, and apply enhanced due diligence to the relationships that warrant it, with senior-management approval and closer monitoring. Screening guidance requires all identified parties to be screened regardless of risk, and sanctions hits to be frozen or escalated without delay.
The reliance chapter carries the most weight for this sector, because advisers routinely sit alongside product providers. The Guidelines distinguish reliance from outsourcing: where an adviser relies on a product provider or another eligible financial institution to perform customer due diligence, it must be satisfied that the third party is regulated and supervised, has adequate measures and will provide the underlying information without delay, and it must still take responsibility for the outcome, including where an acquiring adviser takes over a book. The remaining chapters complete the picture, covering record keeping, suspicious transaction reporting, where the general standard is no later than five business days after suspicion is established, the compliance officer, audit and training scaled to the firm, and a section on proliferation financing that directs an adviser to screen against the latest United Nations Security Council lists, with worked examples in the appendices.
MAS Notice FAA N24 (Specified Financial Advisers, Cross-Border Arrangements)
Issued under the FSM Act, this notice applies to specified financial advisers whose foreign related corporations carry on financial advisory business cross-border under the Financial Advisers cross-border exemption. It is in scope for an adviser that runs such an arrangement, and it requires five-year record-keeping of the related corporation’s due diligence, controls to keep that due diligence consistent with the adviser’s own notice, monitoring of the exemption conditions and the production of records to MAS.
MAS Notice FAA N25 (Licensed and Exempt Financial Advisers, Cross-Border Foreign Offices)
The foreign offices counterpart to FAA N24, for licensed and specified exempt financial advisers operating through their own foreign branches under the cross-border foreign offices exemption. Where an adviser advises cross-border through a foreign office, this notice applies the same cross-border set to that office: five-year record keeping, consistency controls, monitoring of the exemption conditions and provision of records to MAS.
Which AML/CFT notice a financial adviser follows
Whether Notice FAA-N06 applies turns on how the adviser is authorised. The table below sets out the common cases.
How the adviser is authorised | Which AML/CFT notice applies |
Licensed financial adviser (Financial Advisers Act licence) | MAS Notice FAA N06 and its Guidelines |
Registered insurance broker exempt under section 20(1)(c) FAA | MAS Notice FAA N06 and its Guidelines |
Person exempt under regulation 27(1)(d) of the FA Regulations | MAS Notice FAA N06 and its Guidelines |
Adviser that only issues research analyses or reports | Outside Notice FAA N06 (not covered) |
A bank, merchant bank or capital markets licensee advising as an exempt FA | Its own sector notice (for example Notice 626, Notice 1014 or SFA 04 N02). |
An adviser with a foreign related corporation or foreign office | FAA N24 or FAA N25 also applies to the cross-border arrangement |
Allied Laws Applicable to Financial Advisers in Singapore
These statutes are not primarily AML instruments, but each supports the regime: some license and govern financial advisers, while others give investigators their powers, and create the predicate offences and proliferation controls advisers must screen against.
The Financial Advisers Act 2001
This statute establishes the sector. It defines regulated financial advisory services, requires anyone carrying on those services to hold a financial adviser’s licence unless exempt, and sets the sector’s conduct standards. Holding that licence or qualifying for an exemption under the Act is what brings a firm within Notice FAA N06.
The Financial Advisers Regulations 2002
Subsidiary legislation under the Financial Advisers Act setting out the details of licensing, exemptions and conduct of business. It is the source of the regulation 27(1)(d) exemption that Notice FAA N06 refers to, and it forms the regulatory frame within which an adviser’s AML/CFT obligations sit.
The Securities and Futures Act 2001
The Securities and Futures Act defines the capital markets products that financial advisers advise on, so it sets the boundary of much of an adviser’s business. Where an adviser also deals in or manages those products, rather than merely advising, it takes on the corresponding capital markets licence and its AML notice for that activity.
The Securities and Futures (Licensing and Conduct of Business) Regulations 2002
Subsidiary legislation governing how capital markets services are licensed and conducted. It is relevant to financial advisers at the point where their business overlaps with regulated capital markets activity, and it is cross-referred to by the securities notices that can then apply alongside FAA N06.
The Companies Act 1967
Singapore’s general company law statute. What carries weight for AML is its register of registrable controllers’ regime, mirrored in a central ACRA register, which supplies and lets an adviser verify the beneficial ownership picture when it onboards a corporate customer and traces control up to the natural persons behind it.
The Monetary Authority of Singapore Act 1970
The statute that establishes MAS as the central bank and integrated financial regulator. It is where MAS draws the authority to supervise financial advisers and to issue the AML/CFT notices, FAA N06 among them, that the sector must follow.
The Prevention of Corruption Act 1960
Singapore’s main anti-corruption law. Because corruption is a predicate offence for money laundering, the proceeds of offences under it are part of what an adviser looks for in PEP and source of funds checks, and its presumption on unexplained assets reinforces scrutiny of a customer whose wealth does not add up.
The Criminal Procedure Code 2010
The code that arms investigators with production, search and seizure powers. Served with a production order, or an order touching a customer’s property, a financial adviser must comply, keep its records and steer clear of tipping off, which is how an AML investigation reaches into an advisory relationship.
The Strategic Goods (Control) Act 2002
Governs the transfer and brokering of strategic and dual-use goods, the proliferation financing nexus an adviser screens for. Its brokering controls drop away only where a person’s sole role is to provide financing or a financial service, which signals exposure where an adviser’s customer is engaged in more than ordinary trade.
The Biological Agents and Toxins Act 2005
A weapon of mass destruction predicate statute prohibiting the non-peaceful use, production, acquisition or transfer of scheduled biological agents and toxins. For financial advisers, it is one of the offences behind proliferation financing screening, engaged where a customer connects to prohibited biological weapon activity.
The Chemical Weapons (Prohibition) Act 2000
The domestic enactment of Singapore’s Chemical Weapons Convention obligations, making it an offence to use, develop, acquire or transfer chemical weapons, whether directly or through an intermediary. It underpins the proliferation financing checks an adviser runs on its customers and their beneficial owners.
Miscellaneous Laws and Regulations Applicable to Financial Advisers in Singapore
These national strategies, committee reports and typologies set the direction of Singapore’s regime and the partnership an adviser operates within. They carry no binding force, but they direct how MAS supervises and supply many of the typologies an adviser builds into its screening.
National Anti Money Laundering Strategy 2024
Singapore’s national AML blueprint, built on the pillars of Prevent, Detect and Enforce. A financial adviser sits within the Prevent pillar, where MAS commits to risk-based supervision of financial institutions and to the beneficial ownership transparency an adviser relies on for due diligence on corporate customers.
National Strategy for Countering the Financing of Terrorism 2024
Refreshed in 2024 alongside the terrorism financing risk assessment, this five-part strategy covers coordinated risk identification, strong legal and sanctions frameworks, a robust regulatory regime, decisive enforcement and international partnership. It signals the direction an adviser’s terrorism financing controls should take.
National Asset Recovery Strategy 2024
Singapore’s plan to detect, deprive and deliver on the proceeds of crime, noting billions recovered in recent years. A financial adviser plays its part mainly through reporting and cooperation with production orders, since it seldom holds the assets that are restrained.
Singapore Law Enforcement Strategy to Combat Money Laundering (October 2024)
A joint strategy from Singapore’s money laundering investigation agencies, laying out focus areas and key actions and leaning on two-way information flows with financial institutions. It frames the enforcement backdrop an adviser supports through its reporting and its role as a first-line gatekeeper.
Inter Ministerial Committee on Anti Money Laundering Report (October 2024)
Produced after a large money laundering case, this review recommends measures on the misuse of corporate structures, the duties of gatekeepers and better information sharing. Its gatekeeper theme lands squarely on an adviser, which MAS treats as a first line of defence at onboarding.
Legal Persons: Misuse Typologies and Best Practices (2018)
A typologies paper on the ways companies and partnerships get misused, handing an adviser the red flags for beneficial ownership and corporate account checks. It is useful for an adviser that onboards holding companies and special purpose vehicles as customers.
International Standards Applicable to Financial Advisers in Singapore
Singapore’s regime is built to meet the FATF standards, and Notice FAA N06 tracks them closely. These instruments are the least sector-specific of all, yet they explain why the domestic rules look the way they do and hand advisers the typologies and methods supervisors expect them to track.
The FATF Recommendations (updated June 2026)
The Recommendations provide the international AML, CFT and CPF framework that shapes Singapore’s rules for financial advisers. They set the global standards behind key adviser obligations, including customer due diligence, beneficial ownership, politically exposed persons, reliance on third parties and suspicious transaction reporting.
Methodology for Assessing Technical Compliance and Effectiveness (updated June 2026)
The FATF’s assessment methodology is the framework evaluators use to assess a country’s technical compliance with the FATF Recommendations and the effectiveness of its system. For financial advisers, it provides the benchmark against which Singapore’s regulatory framework and supervisory approach are assessed, helping shape the standards MAS expects advisers to meet.
Mutual Evaluation Report of Singapore (May 2026)
The FATF and Asia/Pacific Group’s 2026 mutual evaluation judges how well Singapore’s regime works in practice. It frames supervisory expectations across the financial sector, including the lighter but still real expectations placed on the advisory sector.
FATF Guidance on Politically Exposed Persons (Recommendations 12 and 22, 2013)
Sets out how a firm should spot politically exposed persons and apply enhanced due diligence to them: sign-off from senior management, establishing source of wealth and funds, and closer ongoing monitoring, which advisers apply to the few high-risk customers they onboard.
Guidance on Beneficial Ownership of Legal Persons (March 2023)
Guidance issued under the revised Recommendation 24 on how to identify and verify beneficial ownership information, shaping how advisers are to pin down the beneficial owners of corporate customers and tell legal ownership apart from beneficial ownership.
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 adviser’s reliance on registries and multiple sources when it onboards corporate customers.
Concealment of Beneficial Ownership (July 2018)
A joint FATF and Egmont Group typologies report on how criminals hide beneficial ownership through intermediaries and structures, giving an adviser the red flags to detect concealment behind a corporate customer.
Risk Based Approach: Beneficial Ownership and Transparency of Legal Arrangements (March 2024)
Guidance focused on Recommendation 25 and trusts and similar arrangements, helping advisers assess and mitigate risk when a trust or legal arrangement is the customer, or the owner of a policy it arranges.
FATF Guidance on Counter Proliferation Financing (February 2018)
Guidance explains how financial institutions should implement targeted financial sanctions related to proliferation of weapons of mass destruction under relevant UN Security Council resolutions. For financial advisers, it supports the controls required under FATF Recommendation 7, particularly the need to identify, screen and freeze assets without delay where a designated person or entity is involved.
Guidance on Proliferation Financing Risk Assessment and Mitigation (June 2021)
It sets out how a firm assesses and mitigates proliferation financing risk following the amended Recommendations 1 and 2, which extended risk-assessment duties to proliferation financing across the financial sector.
Guidance on Digital Identity (March 2020)
Helps advisers decide whether a digital identity system is reliable and independent enough for customer due diligence under a risk-based approach, which matters for the remote onboarding many advisory firms now use.
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 and deepfake selfies defeating the remote onboarding an advisory firm depends on, alongside AI’s uses in screening.
Summary of the Key Instruments
The table below distils the instruments financial advisers rely on most, what type each is, whom it binds, and the core obligation it places on the advisers.
Instrument | Type | Who it binds | Core obligation for an adviser |
CDSA 1992 | Statute | All persons and advisers | Report suspicions (STR), do not tip off, keep records |
Terrorism (Suppression of Financing) Act 2002 | Statute | All persons and advisers | Screen out and report terrorist-linked persons |
FSM Sanctions Regulations (DPRK, Iran) 2023 | Regulations | All financial institutions | Screen and freeze designated persons; report to MAS |
MAS Notice FAA-N06 | Notice (FSM Act s16) | Licensed and exempt FAs | Risk-based CDD, EDD, reliance, STR, records, audit |
Guidelines to FAA-N06 | Guidelines | All financial advisers | How to meet the Notice; observance affects MAS assessment |
Financial Advisers Act 2001 | Statute | Financial advisers | Licenses and governs the sector |
Securities and Futures Act 2001 | Statute | Advised products | Defines the capital markets products advised on |
MAS Act 1970 | Statute | MAS and advisers | Source of MAS supervisory authority |
ML, TF and PF NRAs 2024 | Risk assessments | Whole system | Feed the adviser’s enterprise-wide risk assessment |
FATF Recommendations | International standard | Global baseline | Underpin the domestic rules the adviser follows |
Conclusion
For financial advisers in Singapore, the AML, CFT and CPF framework is risk-based and proportionate, but far from optional. The criminal laws establish the offences and reporting obligations, sanctions rules require firms to identify and act on designated persons, and MAS Notice FAA N06 and its guidelines translate these requirements into practical controls covering all the preventive measures. The adviser’s role as a gatekeeper shapes how these controls work. Because financial advisers primarily advise and arrange rather than hold or transfer client funds, their greatest exposure often arises at onboarding
The framework works as a connected system. National risk assessments inform the firm’s risk assessment; Notice FAA N06 drives its compliance controls; the Financial Services and Markets Act 2001 provides the sector’s licensing and regulatory foundation; the FSM Act sanctions regulations; and FATF standards support its targeted financial sanctions and proliferation financing controls.
The key for advisers is therefore not simply having these controls on paper but being able to show that they are risk-sensitive, consistently applied and effective. That is what turns regulatory requirements into a defensible AML, CFT and CPF framework, even in a sector assessed as having relatively low money laundering risk.
Frequently Asked Questions
MAS Notice FAA N06 is the anti-money laundering and countering the financing of terrorism notice for financial advisers, issued under section 16 of the Financial Services and Markets Act 2022. It is read together with the Guidelines to Notice FAA N06, which explain how to meet each requirement.
A licensed financial adviser under the Financial Advisers Act 2001, a registered insurance broker exempt under section 20(1)(c) of that Act, or a person exempt under regulation 27(1)(d) of the Financial Advisers Regulations. A person who only issues research analyses or reports is outside the notice, and an adviser that is also a bank or capital markets licensee follows its own sector notice instead.
Yes. The duty is triggered by establishing business relations, which for an adviser means opening an account or providing financial advice, and by suspicion or doubt, not by moving funds. So even an adviser that only recommends and arranges products must identify and verify its customers and their beneficial owners.
To a degree. Under Notice FAA N06, an adviser may rely on a qualifying third party, such as an insurer or fund manager, or another eligible financial institution, to perform elements of customer due diligence, provided the third party is regulated and will supply the underlying information without delay. The adviser remains responsible for its own obligations, so reliance is not a way to opt out.
Singapore’s 2024 money laundering assessment places financial advisers in the lowest risk band, because they deal largely with retail investors, do not hold customer funds and have limited exposure to higher-risk customers. Even so, MAS treats advisers as important gatekeepers and the first line of defence at the point of onboarding.
Whenever it has reasonable grounds to suspect money laundering or terrorism financing. It must go to the Suspicious Transaction Reporting Office, ordinarily within five business days of the suspicion arising, and within one business day where sanctions are in play. Our guide to STR red flags explains common triggers.
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.
