Key Observations from Enforcement Cases

The cases concluded during this reporting period reveal common enforcement themes. These themes highlight the standards applicable to financial institutions (FIs) and individuals, including licensing obligations, fit and proper criteria and acceptable business conduct, the behaviours and failures that give rise to enforcement action, and the consequences of failing to meet those standards.

Risk-Proportionate Approach to Breaches of Anti-Money Laundering Controls

As a dynamic and trusted international financial centre, Singapore faces inherent risks of money laundering and terrorist financing. To preserve confidence in our financial system, MAS takes a risk-proportionate approach that upholds high regulatory standards while maintaining the sector’s efficiency and competitiveness. MAS urges FIs to maintain robust controls, commensurate with risks posed.

Where FIs fall short of these standards, MAS takes firm enforcement action. MAS has imposed significant financial penalties for Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) control failures, reflecting the nature, severity and impact of the breaches observed. In cases where serious deficiencies were not rectified in a timely manner, MAS took stronger measures, including imposing business restrictions until these deficiencies were remediated, and holding senior management and other key persons responsible accountable.

What these enforcement actions reinforce