In addition, FIs that receive or initiate value transfers will be required to screen both the value transfer originator and the value transfer beneficiary. Imposition of value transfer requirements for DPT or DCMPT services: All FIs engaged in digital token services will be required to comply with the value transfer requirements.for occasional transactions), in relation to digital token services and transactions that the FI is providing to or conducting on behalf of the customer. No minimum threshold for application of CDD requirements for occasional transactions involving DPTs or digital capital market product tokens (“DCMPTs”): MAS clarified that the proposed CDD requirements apply when the FI establishes business relations or undertakes transactions for a customer who has not otherwise established business relations with the FI (i.e.MAS sought views on aligning the existing AML/CFT requirements for banks, merchant banks, finance companies, credit card or charge card licensees and capital markets services licensees in relation to digital token transactions they conduct, with that for digital payment token (“ DPT”) service providers. Proposed alignment of existing AML/CFT requirements with that for digital payment token service providers MAS also clarified that the requirement for FIs to perform the customer due diligence (“ CDD”) measures on occasional transactions with value exceeding S$20,000 may be done on an ex-ante basis. Thus, an FI may use the same account for both regulated dealing and other business activities of a customer, if that is in line with its policy, procedures and business considerations. MAS clarified that FIs are not required to designate separate accounts for each specific business activity of their customers. processing of financial transactions, such as wire transfers, for a customer which is a PSM dealer), would not make an FI an intermediary in regulated dealing. MAS clarified that an FI facilitating its customers’ purchase and sale of PSM, which is understood to be the provision of financial services to customers that are involved with PSMs (i.e. an FI sells PSMs on behalf of its customer). buying PSMs from or selling PSMs to its customers) or is an intermediary in regulated dealing (e.g. In its response, MAS stated that the PSM Notice applies only when an FI itself conducts regulated dealing (i.e. MAS noted that respondents generally supported the proposal. MAS proposed to issue a new notice for FIs dealing in PSMs to ensure consistency in the AML/CFT requirements across all FIs dealing in PSMs, instead of expanding the requirements in the existing AML/CFT notices to apply to the FIs’ PSM activities. New AML/CFT notice for FIs dealing in PSMs Highlights of MAS’ response are set out below.

On 1 March 2022, MAS issued a response to the feedback received, stating that it has incorporated appropriate feedback received into the relevant notices, or will incorporate them into the relevant guidelines accompanying the notices. MAS published a consultation paper on 9 July 2021 seeking feedback on draft versions of the abovementioned notices. On 1 March 2022, the Monetary Authority of Singapore (“ MAS”) issued a new anti-money laundering and countering the financing of terrorism (“ AML/CFT”) notice for financial institutions (“ FIs”) in the conduct of their operations and business activities in precious stones, precious metals and precious products (“ PSM”) (“ PSM Notice”), and revised the existing AML/CFT notices for FIs and variable capital companies (“ VCCs”).

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