As a regulatory compliance professional services firm, Curia Regis provides expert guidance on navigating new regulatory developments to help financial institutions keep abreast of their regulatory obligations. In this brief update, we have provided a summary of the critical points from the latest Monetary Authority of Singapore (MAS) Response on the Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Notice and Guidelines amendments, where such changes were effective as of the 30 June 2025.
Who Must Comply?
All financial institutions in Singapore: banks, payment service providers, capital market intermediaries, trust companies, digital token service providers, and variable capital companies (VCCs), amongst others.
Main Regulatory Updates
1. Proliferation Financing (PF) Compliance
- Financial Institutions (FIs) and VCCs must formally include proliferation financing risks in AML/CFT risk assessments—reflecting upgraded Financial Action Task Force (FATF) standards. While this has already been accorded in existing requirements, this is now to be expressly spelt out.
2. Expanded Trust Company Obligations
- Enhanced data collection and broader definitions for trust companies and trusts (including Trust Relevant Parties), echoing Singapore’s Trustees Act and FATF Recommendation 25.
3. Stricter Suspicious Transaction Reporting (STR) requirements
- Shorter STR deadlines:
- General STRs: 5 business days
- Sanctions-related cases: 1 business day
4. Enhanced Screening & Due Diligence
- Mandatory comprehensive customer screening using native language methods and internet searches.
- Strengthened due diligence on Source of Wealth (SOW) and Source of Funds (SOF) to align with evolving risk standards.
5. Stronger Governance Alignment
- FIs and VCCs must align enterprise-wide risk assessments with national money laundering, terrorism, and proliferation financing assessments, increasing transparency and oversight.
6. Accelerated Implementation
- Effective Date: 30 June 2025. Financial institutions are expected to update compliance frameworks, processes, and controls promptly.
Why Partner with Curia Regis?
Curia Regis specializes in tailored regulatory compliance solutions for Singapore’s dynamic financial services sector, guiding firms through regulatory monitoring, AML/CFT screening, licensing, policy updates, and internal audits. Our local expertise and proactive approach ensure your business aligns with MAS requirements and international best practice.
Compliance Optimization Checklist
| Requirement | MAS 2025 Update | Curia Regis Support |
| AML/CFT Risk Assessment | Explicit inclusion of Proliferation Financing risks | Gap analysis & policy integration |
| STR Deadlines | 5 days (general), 1 day (sanctions) | Policy and Process review & workflow automation |
| Customer Screening & Due Diligence | More comprehensive, multi-language, online checks | Screening solutions & audit readiness |
| Trust Company Data Collection | Expansion to definition of “Trust Relevant Parties” | Enhance Policy and Process to accord for the expansion, including updates on identification and verification methodologies |
| Governance Alignment | Must match national risk assessments | Enterprise-wide risk framework implementation and reivew |
| Implementation | By 30 June 2025 | Project management & training |
Stay Ahead of Singapore’s AML/CFT Changes
Curia Regis can help your Singapore regulated financial institution adapt swiftly and efficiently to these regulatory changes, reducing risk and operational friction. Book a discovery session with our compliance experts to future-proof your business in preparation of MAS’ evolving regulatory landscape.
