30 May 2018

On 14 May 2018, the Anti-Money Laundering (“AML”) and Countering the Financing of Terrorism (“CFT”) Industry Partnership (“ACIP”) announced, at the ACIP Dialogues, the release of a set of best practice papers for financial institutions to guard against trade-based money laundering and the misuse of company structures for illicit purposes.

The two best practice papers (“Papers”) are:

  • “Legal Persons - Misuse Typologies and Best Practices”, which provides information on legal person profiles, legal person misuse typologies, and professional intermediaries; and
  • “Best Practices for Countering Trade Based Money Laundering”, which covers topics such as governance and management oversight, due diligence, transactions surveillance, and suspicious transaction reporting.

In particular, the Papers highlight the “red flag” customer behaviours or transaction patterns that financial institutions can look out for to detect illicit financial activities. The Papers also recommend measures that financial institutions can take to identify or prevent such activities.

These Papers were produced by two industry-led working groups, comprising representatives from major banks, professional service providers and government agencies in Singapore. Professional service providers outside the financial sector, such as lawyers, accountants and company services providers, will also find these recommendations relevant.

All relevant firms are encouraged by the Commercial Affairs Department (“CAD”) and the Monetary Authority of Singapore (“MAS”) to adopt the red flag indicators and recommended measures to strengthen resilience against money-laundering and terrorism-financing risks.

About the ACIP

By way of background, the ACIP was set up in April 2017. It is co-chaired by CAD and MAS, and is supported by a steering group comprising eight banks and the Association of Banks in Singapore (“ABS”). The ACIP brings together both stakeholders from industry and government and provides a dedicated platform to discuss key transnational illicit finance risks confronting Singapore’s financial and non-financial sectors, as well as identify and promote areas to uplift money-laundering and terrorism-financing risk understanding in Singapore.

Reference materials

The following materials are available on the MAS website www.mas.gov.sg and the ABS website www.abs.org.sg:


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