AML Supervision by the Monetary Authority of Singapore (MAS)
In a Nutshell
MAS is Singapore’s central bank and integrated financial regulator, and the principal AML/CFT supervisor for financial institutions within its regulatory remit.
It supervises banks, merchant banks, finance companies, insurers, capital markets entities, financial advisers, trust companies, payment service providers, digital payment token service providers and other financial institutions within its regulatory remit. MAS imposes binding AML/CFT requirements through applicable legislation and Notices and sets out supervisory expectations through Guidelines and other guidance
One important exception: MAS does not supervise licensed moneylenders. That falls to the Ministry of Law, even though moneylending is a financial activity.
MAS supervises through a risk based cycle: licensing, offsite surveillance, onsite inspections, thematic reviews and published guidance, escalating to remediation and enforcement. Its July 2025 action against nine financial institutions, following the 2023 money laundering case, shows the enforcement end of that cycle.
AML Supervision by the Monetary Authority of Singapore
The Monetary Authority of Singapore is the single most important AML/CFT supervisor in the country, because the financial sector it oversees is where most value moves. But it is not the only supervisor, nor is it a universal AML regulator. MAS supervises financial institutions; other bodies supervise the non financial sectors, and even one financial activity, licensed moneylending, falls outside its remit. This guide explains exactly what MAS does as an AML/CFT/CPF supervisor: whom it covers, the rulebook it enforces, how it assesses risk and inspects, what it now expects following recent inspections, and how it enforces when firms fall short.
If you want the position of every supervisor in one place, start with the guide to Singapore’s AML supervisory authorities. For the underlying statutes and rules, see the guide to AML Laws and Regulations pillar. This page is about MAS as the financial sector supervisor.
The Financial Sector MAS Supervises in Numbers
Singapore’s financial sector is exposed to significant money laundering risks because of the scale and international nature of its financial activities. Singapore’s 2024 Money Laundering National Risk Assessment identifies banking, including wealth management, as presenting the highest money laundering risks in Singapore. The assessment also identifies other financial sectors and activities with different levels of money laundering risk. (From the ML National Risk Assessment 2024.)
Where MAS Sits in the National Architecture
MAS is Singapore’s central bank and regulates financial institutions across the banking, capital markets, insurance and payments sectors. It also supervises financial institutions within its regulatory remit for AML/CFT purposes. This integrated regulatory structure allows MAS to consider AML/CFT risks alongside other regulatory and supervisory matters.
Its AML/CFT powers arise from the sector specific legislation governing financial institutions and the Financial Services and Markets Act 2022. Section 16 of the Financial Services and Markets Act 2022 provides for MAS to issue directions concerning the prevention of money laundering and terrorism financing. Financial institutions that fail or refuse to comply with applicable AML/CFT requirements in a MAS Notice may commit an offence and may be liable on conviction to a fine not exceeding S$1 million for each offence, with an additional fine of S$100,000 for every day or part of a day during which a continuing offence continues after conviction. Sector specific MAS Notices set out the applicable AML/CFT requirements for the relevant financial institutions.
At the national level, MAS is one of the key agencies involved in Singapore’s AML effort. It works with the Ministry of Home Affairs and the Ministry of Finance through the AML/CFT Steering Committee. MAS therefore has both supervisory responsibilities for financial institutions within its regulatory remit and a role in Singapore’s wider national AML/CFT framework.
The integrated model has a practical consequence for financial crime supervision. Because the same authority authorises a firm, sets its prudential requirements and inspects its AML/CFT controls, MAS can connect a firm’s business model, its risk appetite and its financial crime controls into a single supervisory view. A weakness in governance that a prudential supervisor might notice is available to the AML supervisor too, and vice versa. This is one reason MAS places so much weight on senior management accountability: the same board that owns the firm’s strategy owns its financial crime controls, and MAS supervises both.
We help regulated entities build proportionate CDD, record keeping and reporting controls that satisfy the MAS without drowning in paperwork.
Who MAS Supervises for AML/CFT/CPF
MAS supervises financial institutions that fall within its regulatory remit and are subject to applicable AML/CFT requirements. MAS has issued sector and entity specific AML/CFT Notices for different categories of financial institutions. The table below identifies the principal Notices for the main categories and is not a complete statement of all applicable requirements. The applicable Notice and current version should be checked against the MAS website before reliance.
Financial institution type | Principal AML/CFT Notice | Note |
Banks | MAS Notice 626 | The flagship AML/CFT Notice |
Merchant Banks | MAS Notice 1014 | Aligned with the bank Notice |
Finance Companies | MAS Notice 824 | Read with its corresponding guidelines |
Capital Markets Services Licensees | MAS Notice SFA 04 N02 | Covers fund managers, dealers and others |
Financial Advisers | MAS Notice FAA N06 | Read with its corresponding guidelines |
Direct Life Insurers | MAS Notice 314 | Read with its corresponding guidelines |
Licensed Trust Companies | MAS Notice TCA N03 | Read with its corresponding guidelines |
Payment Service Providers | MAS Notice PSN01 | Read with its corresponding guidelines |
Digital Payment Token Service Providers | MAS Notice PSN02 | Higher risk sector in the ML NRA 2024 |
Non Bank Credit Card Issuers | MAS Notice 626A | Read with its corresponding guidelines |
The Securities Depository | MAS Notice SFA 03AA N01 | Read with its corresponding guidelines |
Variable Capital Companies | MAS Notice VCC N01 | Read with its corresponding guidelines |
The exception that trips people up is moneylending. A licensed moneylender is carrying on a financial activity, but it is supervised by the Ministry of Law’s Registry of Moneylenders, not by MAS. If you lend under the Moneylenders Act, MAS is not your AML supervisor.
Boundary: MAS Does Not Supervise Licensed Moneylenders
Licensed moneylenders answer to the Registry of Moneylenders at the Ministry of Law, not to MAS. This is the main case where a financial activity sits outside MAS’s AML/CFT remit. Everything in this guide about MAS supervision does not apply to a licensed moneylender; read the Ministry of Law guide instead.
The MAS AML Rulebook Hierarchy
MAS’s AML expectations are not a single document. They are a stack, and knowing which layer you are reading matters, because only some of it is legally binding. The figure below sets out the hierarchy.
At the top sit the sector statutes and the Financial Services and Markets Act 2022, which provide MAS with its regulatory powers. Applicable AML/CFT Notices then set binding requirements for the financial institutions to which they apply. There is not necessarily one AML/CFT Notice for every sector. Different types of financial institutions may be subject to different Notices. For example, Notice 626 applies to specified banks, while Notice PSN01 applies to specified payment services and Notice PSN02 applies to digital payment token services. Treating Notice 626 as a universal MAS requirement is therefore incorrect.
Beneath the applicable legislation and Notices are Guidelines, circulars and information papers through which MAS communicates its supervisory expectations and good practices. The Guidelines explain MAS’s expectations for complying with the applicable Notices, while circulars and information papers provide additional guidance on risks and supervisory issues. These materials do not have the same legal status as binding statutory requirements or requirements contained in applicable MAS Notices. MAS’s October 2024 information paper states that financial institutions should benchmark their AML/CFT frameworks and controls against the supervisory expectations and good practices identified in the paper.
How MAS Risk Rates and Supervises
MAS supervises financial institutions using a risk based approach. Its supervisory approach considers the risks associated with a financial institution’s business, customers, products, services and delivery channels and helps determine the areas requiring supervisory attention. The frequency and scope of supervisory work may therefore vary according to the risks identified and other supervisory considerations.
The cycle begins at the licensing or authorisation stage, where MAS assesses applications and applies applicable regulatory and fit and proper requirements. Once a financial institution is admitted, MAS conducts offsite supervision using regulatory returns, data submissions, questionnaires and other supervisory information to identify areas requiring further attention. Onsite inspections test whether the controls described in policies and procedures operate effectively in practice. MAS’s October 2024 information paper identifies customer due diligence, ongoing monitoring and risk mitigation among the areas examined during recent AML/CFT inspections.
Alongside firm by firm supervision, MAS conducts thematic inspections and publishes information papers setting out supervisory expectations and good practices. Where supervisory work identifies deficiencies, MAS may require the financial institution to take remedial action and may take further supervisory or enforcement action where appropriate. MAS uses supervisory findings and information to support its risk based supervisory approach.
Two features of MAS supervision are the use of supervisory information and independent assurance. MAS uses supervisory information as part of its risk based supervisory approach. MAS also expects financial institutions to maintain appropriate independent assurance over their AML/CFT frameworks and controls, subject to the applicable requirements and the institution’s circumstances and risk profile. Where an independent review identifies deficiencies, the financial institution should address them appropriately and demonstrate effective remediation.
Information Sharing and Intelligence
MAS also plays an important role in Singapore’s financial crime information sharing framework. COSMIC, or Collaborative Sharing of ML/TF Information and Cases, is a digital platform through which participating financial institutions can securely share information in accordance with the applicable statutory framework. The platform is intended to strengthen the detection and prevention of financial crime by facilitating information sharing between participating financial institutions where the applicable conditions are met.
The second system is the suspicious transaction report. A person who knows or has reasonable grounds to suspect that any property may be connected to criminal activity is required to file a suspicious transaction report with the Suspicious Transaction Reporting Office. Information relating to terrorism financing may also be disclosed to STRO under the applicable requirements. STRs are filed electronically through the SONAR platform. This reporting obligation is separate from information sharing through COSMIC, and sharing information through COSMIC does not replace an applicable obligation to file an STR with STRO.
We stress test AML/CFT frameworks against exactly what MAS inspects, customer risk assessment, source of wealth, monitoring and reporting, and help close the gaps before an inspection does.
Supervisory Expectations from Recent Inspections
In October 2024, MAS published an information paper setting out its supervisory expectations from recent AML/CFT inspections. It does not impose new obligations, but it tells firms exactly where inspectors have found weaknesses and what MAS expects instead. Firms are told to benchmark against it, conduct a risk proportionate gap analysis, and have senior management oversee the fixes. It singles out five areas.
First, the assessment of customer risk. MAS expects financial institutions to understand their customers’ profiles sufficiently to assess ML and TF risks at onboarding and during ongoing monitoring. In its October 2024 information paper, MAS highlighted customers with multiple nationalities, including nationality obtained through citizenship or residency by investment schemes. MAS does not expect customers with multiple nationalities to be treated as higher risk by default. Instead, financial institutions should consider relevant risk factors, including frequent changes in nationality or key identifiers, information suggesting that previous nationalities or identities may have been withheld, higher risk citizenship or residency by investment schemes, adverse news and material discrepancies in customer information.
Second, the identification of material red flags. MAS expects financial institutions to have appropriate processes for identifying and escalating material red flags, including discrepancies in customer information and supporting documents and other information that may indicate heightened ML or TF risk. Financial institutions should ensure that relevant staff understand applicable red flags and escalation processes and that appropriate controls are in place to identify and address potential concerns.
Third, the establishment of source of wealth. MAS expects financial institutions to apply appropriate rigour in assessing and establishing a customer’s source of wealth in accordance with the applicable requirements and the customer’s risk profile. Where applicable requirements and the risk assessment call for corroboration, financial institutions should obtain and assess appropriate corroborating information. MAS’s July 2025 enforcement action identified deficiencies relating to the establishment and corroboration of source of wealth among the financial institutions subject to the action.
Fourth, risk mitigation measures. MAS expects financial institutions to take appropriate risk mitigation measures where ML or TF risks have been identified, including in circumstances involving suspicious transactions. The measures should be commensurate with the risks identified and the applicable regulatory requirements.
Fifth, holistic monitoring. Financial institutions should have appropriate processes to identify and assess relevant customer information across business units and related accounts where necessary to identify and manage ML and TF risks. MAS’s October 2024 information paper sets out supervisory expectations and good practices arising from recent AML/CFT inspections and states that financial institutions should benchmark their AML/CFT frameworks and controls against those expectations.
The paper also records good practices MAS observed, which are worth copying because they show the standard in concrete terms. Some firms required customers to declare all current and previous nationalities at onboarding and asked for evidence such as proof of renunciation, rather than accepting a single declaration. Vigilant compliance staff caught material discrepancies on live files: a web domain that remained in use and was marketed at a fraction of its purported sale price despite being sold; a company whose business licence description did not match the customer’s account of its business; shareholding dates that differed between the customer’s representations and an independent corporate report; and bank statements with missing descriptors. None of this required forensic skill; they required staff who were trained to look, guidance that told them what to look for, and a clear route to escalate. That is the bar MAS is setting.
The MAS Compliance Calendar
There is no single MAS AML calendar that applies to every financial institution. AML/CFT requirements include event driven obligations as well as ongoing and periodic controls and sector specific regulatory returns. The applicable requirements and their timing depend on the financial institution, its regulated activities and the applicable legislation, Notices and regulatory requirements. Firms should confirm the relevant requirements against the MAS regulatory framework and applicable Notices.
Duty type | Examples | Cadence |
Event driven | Customer due diligence at onboarding; sanctions and PEP screening; enhanced due diligence for higher risk; suspicious transaction reports to STRO; targeted financial sanctions freezes | Triggered by the event, a new customer, a screening hit, a suspicion, a designation, not by a calendar date |
Periodic controls | Enterprise wide risk assessment refresh; independent audit of AML/CFT controls; staff training; board and senior management reporting | On a risk based cycle set by the Notice and the firm’s policy |
Sector specific returns and data | Regulatory returns, risk questionnaires and thematic data requests that differ by financial institution type | As required by MAS for the sector, plus ad hoc data requests |
Targeted financial sanctions obligations may require financial institutions to act without delay when the applicable sanctions requirements are triggered. Suspicious transaction reports must be filed as soon as reasonably practicable after the relevant suspicion arises. These obligations are generally triggered by the relevant event or circumstances rather than by a fixed monthly or annual reporting cycle.
MAS and the National Strategy
MAS’s supervision is informed by Singapore’s national risk assessment and its risk based supervisory approach. Singapore’s 2024 Money Laundering National Risk Assessment identifies banking, including wealth management, as presenting high money laundering risks and identifies other financial sectors and activities with different levels of risk. These assessments help inform Singapore’s broader AML/CFT risk mitigation framework, but they do not determine the risk rating of every individual financial institution or customer. The sectoral risk assessment for financial institutions breaks this down further across sub sectors.
Other financial sectors have also been assessed as presenting higher ML risks. Singapore’s 2024 ML National Risk Assessment identifies digital payment token service providers, payment institutions providing cross border money transfer services and external asset managers as higher risk financial sectors. The assessment also identifies banks, including wealth management, as presenting the highest ML risks in Singapore. The PF National Risk Assessment separately identifies banks, digital payment token service providers, remittance agents and maritime insurers as financial sectors exposed to higher PF risks. These assessments inform risk based supervisory and compliance priorities, but a higher risk sector classification does not mean that every individual institution or customer within that sector has the same risk profile.
Wealth management deserves particular attention because Singapore’s 2024 ML National Risk Assessment identifies banking, including wealth management, as posing the highest ML risks in Singapore. The assessment also identifies external asset managers and licensed trust companies as higher risk areas. MAS has issued supervisory expectations concerning source of wealth and other controls relevant to higher risk customers. However, firms should apply a risk based assessment rather than automatically treating every firm or relationship connected with wealth management as higher risk.
Enforcement Powers and Outcomes
MAS has a range of supervisory and enforcement tools for AML/CFT breaches. Depending on the applicable legislation and circumstances, these may include composition penalties, directions, supervisory measures, licensing or regulatory action and prohibition orders against individuals. Breaches of applicable AML/CFT requirements may also constitute offences under the relevant legislation. The Financial Services and Markets Act 2022 provides for prohibition orders and offences relating to requirements issued under the Act. Criminal investigations and prosecutions may involve MAS and other law enforcement authorities depending on the nature of the conduct and the applicable offence.
These routes may operate separately or together, depending on the circumstances and the applicable legislation. MAS may take regulatory or enforcement action against financial institutions and individuals, including composition penalties, prohibition orders and other regulatory measures. Criminal investigations or prosecutions may also arise where the conduct potentially constitutes a criminal offence. MAS’s July 2025 enforcement action included composition penalties against nine financial institutions and regulatory action against individuals.
It is important to distinguish statutory maximum penalties from the amounts imposed through composition or other enforcement action. For example, Section 16 of the Financial Services and Markets Act 2022 provides for a maximum fine of S$1 million for an offence involving specified AML requirements under that section, with an additional fine for a continuing offence after conviction. The actual composition amount may be lower and depends on the applicable statutory framework and circumstances of the case. MAS also expects financial institutions to remediate deficiencies identified through supervision.
Enforcement Timeline: The 2023 Case and the 2025 Penalties
The clearest illustration of MAS enforcement is the supervisory follow up to Singapore’s 2023 money laundering case. MAS conducted supervisory examinations and investigations of relevant regulated entities and associated individuals. On 4 July 2025, MAS announced regulatory actions against nine financial institutions for AML related breaches, including composition penalties totalling S$27.45 million.
When | What happened |
August 2023 | Singapore’s largest money laundering case surfaces, with around S$3 billion in assets seized and multiple individuals arrested |
2023 to 2025 | MAS conducts supervisory examinations of the financial institutions through which the funds moved |
October 2024 | MAS publishes its Supervisory Expectations from Recent Inspections paper, setting out the control weaknesses it wants fixed |
4 July 2025 | MAS imposes composition penalties totalling S$27.45 million on nine financial institutions for AML/CFT control failings connected to the case, and acts against individuals |
From 2025 | MAS updates its supervisory expectations and continues to press the sector on customer risk assessment, source of wealth, transaction monitoring and reporting |
The July 2025 enforcement actions are significant because MAS identified AML/CFT control deficiencies in areas including customer risk assessment, establishing and corroborating source of wealth, transaction monitoring and risk mitigation. MAS stated that the deficiencies were identified during supervisory examinations conducted from early 2023 to early 2025. The enforcement action should therefore be read together with MAS’s supervisory expectations concerning these areas.
MAS, STRO and Law Enforcement: Who Does What
Three functions should be distinguished. MAS supervises financial institutions within its regulatory remit and oversees their AML/CFT controls. The Suspicious Transaction Reporting Office is Singapore’s financial intelligence unit and receives suspicious transaction reports through SONAR. Reports filed through SONAR are received by STRO and used as financial intelligence. STRO is not the AML/CFT supervisor of MAS regulated financial institutions. Relevant law enforcement agencies, including the Commercial Affairs Department of the Singapore Police Force where applicable, may investigate suspected money laundering offences; prosecutions are conducted through the criminal justice system.
For a bank, MAS is the financial sector supervisor responsible for supervising its AML/CFT controls. STRO is Singapore’s financial intelligence unit and receives and analyses STRs and other financial information. Where a potential offence is identified, relevant law enforcement agencies may investigate the matter. The functions can therefore interact in the same case, but the supervisory, financial intelligence and law enforcement roles are distinct.
Putting Supervision into Practice
What a MAS Inspector Looks at on Your Files
Customer risk assessment: whether higher risk customers are correctly rated and the enterprise wide assessment is real rather than a template.
Source of wealth: whether the documented source is corroborated for high risk clients, not merely collected.
Transaction monitoring: whether the system is tuned and resourced, and whether alerts are examined and closed.
Report follows through: whether concerns are escalated, decided and, where needed, filed, with a clear audit trail.
Oversight of outsourcing: whether the firm keeps independent sight of any outsourced AML work.
Worked Example (Illustrative)
A private banking team onboards a client with two nationalities and a large inbound transfer. The file records a declared source of wealth but does not contain appropriate corroborating information, and a screening alert is closed without adequate investigation. During an inspection, MAS could identify deficiencies in the financial institution’s customer risk assessment, source of wealth assessment or screening controls, depending on the facts and applicable requirements. MAS’s October 2024 information paper and subsequent enforcement actions highlight the importance of effective controls in these areas.
Your Reporting Line: STRO
Whoever supervises you, you report suspicion to the same place. Where the applicable suspicious transaction reporting obligation is triggered, a suspicious transaction report must be filed with the Suspicious Transaction Reporting Office as soon as reasonably practicable after the relevant suspicion arises. STRs are filed electronically through the SONAR platform.
Frequently Asked Questions
MAS is the principal AML/CFT supervisor for the financial sector. It regulates and supervises financial institutions within its remit, issues binding AML/CFT requirements through applicable legislation and Notices, conducts risk based supervision and inspections, publishes supervisory expectations and takes appropriate supervisory and enforcement action where deficiencies or breaches are identified. Guidelines and other supervisory materials should not be described as binding in the same way as Notices and statutory requirements.
Banks, merchant banks, finance companies, insurers, capital markets services licensees, financial advisers, licensed trust companies, payment service providers, digital payment token service providers, the securities depository, variable capital companies and other financial institutions within MAS’s regulatory remit are subject to applicable AML/CFT requirements. The applicable Notice depends on the type of financial institution and regulated activity, and there may be more than one applicable Notice or regulatory instrument.
No. The Ministry of Law’s Registry of Moneylenders supervises licensed moneylenders, not MAS, even though moneylending is a financial activity.
No. Notice 626 applies to the categories of banks specified in the Notice. Other financial institutions are subject to the AML/CFT requirements applicable to their respective sectors and regulated activities. For example, Notice PSN02 applies to digital payment token services, while Notice SFA04 N02 applies to capital markets intermediaries.
A MAS Notice sets binding regulatory requirements issued under the applicable legislation. Guidelines explain MAS’s supervisory expectations relating to the applicable Notices, while circulars and information papers provide additional supervisory guidance and expectations. These materials do not have the same legal status as statutory requirements or binding requirements contained in applicable Notices. MAS expects financial institutions to benchmark their AML/CFT frameworks and controls against the supervisory expectations and good practices identified in its information papers.
MAS conducts AML/CFT supervision using a risk based approach. It uses supervisory information to identify areas requiring attention and conducts inspections to assess the effectiveness of financial institutions’ AML/CFT frameworks and controls. MAS also conducts thematic work and expects financial institutions to address deficiencies identified through supervision.
Yes. Depending on the applicable legislation and circumstances, MAS can take enforcement action including composition penalties, directions, licensing or regulatory action and prohibition orders against individuals. Applicable AML/CFT breaches may also constitute offences. In July 2025, MAS imposed composition penalties totalling S$27.45 million on nine financial institutions for AML/CFT breaches.
COSMIC is a digital platform that enables participating financial institutions to securely share information about customers who exhibit multiple red flags that may indicate potential financial crime concerns, where the applicable thresholds are met. Reporting suspicious transactions to STRO is a separate legal obligation. Information sharing through COSMIC does not replace or discharge an applicable obligation to file an STR with STRO.
They inform Singapore’s risk based AML/CFT framework and help inform supervisory and risk mitigation priorities. Singapore’s 2024 ML National Risk Assessment identifies banking, including wealth management, as presenting the highest ML risks in Singapore and identifies digital payment token service providers, payment institutions providing cross border money transfer services and external asset managers as higher risk financial sectors. A sector level risk classification does not mean that every financial institution or customer within that sector has the same individual risk profile.
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.
