Name
Global FinTech Guide
Country _ Name
Singapore
SectionTitle
KYC requirements
Body
The know your customer or know your client (KYC) guidelines and regulations for financial services require that professionals try to verify the identity, suitability, and risks involved with maintaining a business relationship.

Legal affairs

National regulatory framework regarding AML and effective date of the regulations

The primary AML legislation in Singapore is the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 which covers AML associated with serious crimes. Notwithstanding this, there is no singular regulatory framework for AML/KYC in Singapore and the relevant framework applicable to an entity and business relationship depends on various factors, a common one being whether the activity involved is regulated by legislation under which an authority is given supervisory powers.
The regular notices, guidelines and announcements issued by the Monetary Authority of Singapore (MAS) are regarded as the primary source of regulations AML obligations of financial institutions in Singapore. These notices, guidelines and announcements set out the latest updated AML obligations and are binding on financial institutions. Non-compliance by a financial institution may result in significant financial penalties.
Other legislation containing AML obligations that may be applicable to financial services include the following:

  • Casino Control Act 2006 applicable to Casinos;
  • Moneylenders Act 2008 applicable to Moneylenders; and
  • Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019 applicable to dealers of precious stones and precious metals.

National regulator or relevant authority for AML controls

The MAS is the regulator and supervisor of financial institutions in Singapore. However, other authorities that may be relevant and have AML supervisory powers depending on the activity conducted include but are not limited to the Accounting and Corporate Regulatory Authority, Gambling Regulatory Authority and Ministry of Law.


Customer Due Diligence

Conduct of a typical KYC identification process

The typical KYC identification process requires collecting personal particulars and documentation from the customer/client and identifying the ultimate beneficial owner.

Personal particulars generally include accepted (for natural persons or legal persons/arrangements, as applicable): (i) full name of person/entity; (ii) birth date/incorporation date; (iii) nationality; (iv) national ID (if Singapore resident)/passport number; (v) home address; (vi) occupation; (vii) address; and (viii) telephone number.

As for identification documents, certified true copies of the following are generally accepted (for natural persons or legal persons/arrangements, as applicable): (i) national identity card (if Singapore resident); (ii) passport; (iii) certificate of incumbency; (iv) certificate of good standing; (v) share register; (vi) certificate of incorporation.

Certified true copies must be produced by a suitably qualified person (e.g. a notary public, a lawyer or certified public or professional accountant).

Possibility to meet customer due diligence requirements by relying on third parties who are obliged by law themselves to comply with AML regulations

Financial institutions are permitted to outsource customer due diligence to a third party obliged by law themselves to comply with AML regulations. However, the financial institution is ultimately responsible and accountable to MAS to ensure that all aspects of the financial institution’s AML/CFT policies and procedures comply with all applicable AML/CFT regulations. Accordingly, the financial institution must ensure that the third party’s standards of due diligence are competent and sufficient for the purposes of the financial institution’s wider obligation to meet the prescribed requirements by the Monetary Authority of Singapore (MAS).

Possibility to outsource customer due diligence by contract to other third parties who are not obliged by law to meet AML regulations and rely on these (e.g., WebID, IDnow, PostIdent)

Financial institutions are permitted to outsource this. Ultimately it is the financial institution that is responsible and accountable to MAS to ensure that it complies with all applicable AML/CFT regulations.

Presence of a license or registration requirement for the third party in case of outsourcing customer due diligence

No license nor registration is required for third parties to provide such outsourcing services.


Further questions

Entities that could be relied on specifically by law as a third party to comply with AML regulations (regardless of outsourcing)


Yes credit institutions
Yes financial institutions
Yes auditors, external accountants, and tax advisors
Yes notaries and other independent legal professionals
Yes other trust or company service providers
Yes estate agents
  other persons trading high-value goods
Yes providers of gambling services


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