Guidance
Published Date: 24 September 2018

Guidance for Effective AML/CFT Transaction Monitoring Controls

Sets out MAS' recommendations to inspected banks and supervisory expectations of sound practices for effective transaction monitoring.
Applies to: Credit/Charge Card Issuer , Finance Company , Full Bank (Branch) , Full Bank (Locally Incorporated) , Merchant Bank (Branch) , Merchant Bank (Locally Incorporated) , Wholesale Bank (Branch) , Wholesale Bank (Locally Incorporated) , Financial Holding Company , Exempt Trust Company , Licensed Trust Company , Exempt Person Providing Trust Services , Approved CIS Trustee , Central Securities Depository , Corporate Finance Advisory , Credit Rating Agency , Dealing in Capital Markets Products , Exempt Capital Markets Services Entity , Exempt Corporate Finance Adviser Serving Accredited Investors , Exempt Futures Broker , Exempt OTC Derivatives Broker , Foreign Fund Manager , Licensed Fund Management Company , Members of Public , Markets and Exchanges , OTC Counterparties , Money Broker , Product Financing , Providing Custodial Services , Registered Business Trust , Registered Fund Management Company , REIT Management , Securities Crowdfunding , Venture Capital Fund Management Company , Exempt Financial Adviser , Exempt Financial Adviser Serving up to 30 Accredited Investors , Licensed Financial Adviser , Direct Insurer (Life) , Direct Insurer (General) , Direct Insurer (Composite) , Reinsurer (Life) , Reinsurer (General) , Reinsurer (Composite) , Captive Insurer , Lloyd's Asia Scheme , Authorised Reinsurer , Representative Office (Insurance) , Approved MAT Insurer , Financial Holding Company (Insurance) , Registered Insurance Broker , Exempt Insurance Broker , Approved Insurance Broker , Lloyd's Broker , Technology , Credit and Charge Card Licensee , Designated Payment System Operator , Designated Payment System Settlement Institution , Standard Payment Institution , Major Payment Institution , Money-changing Licensee

MAS conducted a series of thematic AML/CFT inspections that examined the effectiveness of banks’ transaction monitoring (“TM”) frameworks and processes. This guidance paper reiterates the key recommendations by MAS to the inspected banks, setting out our supervisory expectations of sound practices for the effective conduct of TM. Additional context can be found in the box stories throughout the paper of case studies taken from MAS’ onsite findings and our recommendations to financial institutions ("FIs").

While this guidance paper is derived from MAS’ banking inspection findings, the supervisory expectations and best practices therein are, with the appropriate modifications, relevant and applicable to other FIs. FIs should therefore incorporate the learning points from this guidance paper in a risk-based and proportionate manner, giving proper regard to the profile of their business activities and customers. In doing so, FIs should note that the takeaways in this paper are non-exhaustive, and that they should continue to strengthen and refine their TM models according to their respective needs and context.

Infographic on Effective AML/CFT Transaction Monitoring Controls (261.4 KB)