MAS conducted a series of thematic inspections of PBs targeted at assessing the effectiveness of their AML/CFT risk management and controls. This guidance paper sets out MAS’ supervisory expectations of effective AML/CFT controls in the private banking industry, and includes illustrative examples taken from MAS’ inspections.

While this paper is derived from the inspections of PBs, the takeaways are applicable and relevant to other types of financial institutions (“FIs”), with the appropriate calibrations. All FIs should therefore study and incorporate learning points from this guidance in a risk-based and proportionate manner. FIs should also note that the findings and examples highlighted in this paper are non-exhaustive, and FIs should continue to implement appropriate AML/CFT controls that are commensurate with the nature and complexity of their business.