MAS Notice 626 vs HKMA AML-2: a side-by-side compliance map.
Singapore and Hong Kong share FATF-aligned AML/CFT objectives, but the controlling instruments, terminology, local reporting channels and operational requirements are not interchangeable. Compare them at requirement level and keep each conclusion tied to its source.
Quick answer: use a shared control taxonomy, but preserve separate source text, applicability decisions and local procedures. A similar control objective does not make two requirements legally equivalent.
What each source is
MAS Notice 626 is the Monetary Authority of Singapore’s AML/CFT notice for banks. It should be read with its Guidelines, relevant Singapore legislation, targeted financial-sanctions requirements and applicable MAS communications.
HKMA AML-2 is the Guideline on Anti-Money Laundering and Counter-Financing of Terrorism for Authorized Institutions. It operates alongside Hong Kong’s Anti-Money Laundering and Counter-Terrorist Financing Ordinance, Banking Ordinance and relevant guidance.
Because these source structures differ, do not compare labels alone. Preserve the instrument, paragraph, version and effective date behind every mapped obligation.
Where the control objectives align
- Enterprise and customer risk assessment.
- Customer identification, verification and beneficial-ownership review.
- Enhanced measures for higher-risk relationships and politically exposed persons.
- Ongoing monitoring and investigation of unusual activity.
- Suspicious transaction escalation and reporting.
- Correspondent banking, wire-transfer and intermediary controls.
- Records, training, governance, compliance monitoring and independent assurance.
These common themes support a shared control library, but only after each requirement has been reviewed in its local context.
Where teams need a jurisdiction-specific view
Source hierarchy and legal form
Separate binding requirements, statutory provisions, guidelines and supervisory communications. Record how each source is used in the applicability decision instead of flattening them into a single “rule.”
Definitions and risk classification
Compare the exact definitions used for customer, beneficial owner, politically exposed person, higher-risk relationship and related concepts. Differences in wording can change onboarding, approval and review workflows.
CDD and enhanced measures
Map identity, ownership and control requirements at paragraph level. Preserve conditions, exceptions, approval requirements and evidence expectations rather than relying on one group-standard summary.
Reporting, records and local channels
Keep local escalation, reporting authority, timing, confidentiality and retention logic visible. Workflows and system rules should reference the controlling local source and current approved procedure.
Sanctions and associated requirements
Maintain the connection between AML/CFT obligations and separate targeted financial-sanctions requirements without implying they arise from the same instrument.
A practical comparison matrix
For each topic, retain the MAS source, HKMA source, plain-language obligation, applicability, material difference, policy, procedure, control, system, owner, evidence and last review date. Mark a mapping “shared” only when the underlying control genuinely satisfies both reviewed requirements.
| Obligation topic | MAS source location | HKMA AML-2 source location | Operating-model implication |
|---|---|---|---|
| Enterprise ML/TF risk assessment | Notice 626 paragraph 4 | Chapter 2 — risk-based approach | One regional methodology can be used, but local entity, product, channel and geography evidence must remain identifiable. |
| AML/CFT governance and systems | Notice 626 paragraph 15 | Chapter 3 — AML/CFT systems | Preserve local compliance-officer, management, audit, training and escalation accountability. |
| Customer identification and verification | Notice 626 paragraph 6 | Chapter 4 — customer due diligence | Map local identification evidence, exceptions, timing and failure-to-complete workflow. |
| Beneficial ownership | Notice 626 paragraph 6 | Chapter 4.4 — beneficial owner | Do not assume ownership thresholds, control tests or legal-arrangement steps are identical. |
| PEPs and higher-risk relationships | Notice 626 paragraph 8 | Chapter 4.9 and enhanced CDD provisions | Localise PEP categories, source-of-wealth/source-of-funds evidence, approval and monitoring. |
| Ongoing monitoring | Notice 626 paragraph 6 and applicable enhanced measures | Chapter 5 — ongoing monitoring | Keep transaction-monitoring, CDD refresh and event-trigger logic tied to local procedures. |
| Suspicious transaction reporting | Notice 626 paragraph 14 | Chapter 7 — STRs and law-enforcement requests | Use local escalation, reporting authority, confidentiality, copy and retention rules. |
| Record keeping | Notice 626 record-retention provisions; verify current paragraph | Chapter 8 — record-keeping | Set system retention from the current local rule and preserve evidence of extensions or holds. |
| Wire transfers | Notice 626 paragraph 11 | Chapter 10 — wire transfers | Configure message fields, thresholds, missing-information decisions and screening by jurisdiction. |
| Correspondent banking | Notice 626 paragraph 10 | Chapter 11 — correspondent banking | Localise respondent due diligence, approval, payable-through, shell-bank and review requirements. |
| Third-party reliance | Notice 626 paragraph 9 | Chapter 4 third-party CDD provisions | Record when reliance is permitted, document retrieval obligations and retained responsibility. |
| Sanctions, TF and proliferation financing | Notice 626 plus separate Singapore laws, regulations and directions | Chapter 6 plus Hong Kong legal measures | Keep related controls connected without misattributing a sanctions duty to the AML guideline. |
Source note: the MAS paragraph labels follow the Notice structure; the HKMA labels follow AML-2. Confirm the current official versions and exact subparagraphs before turning this table into a legal inventory.
- Confirm the current official source and version for each jurisdiction.
- Extract obligations without removing conditions or exceptions.
- Compare requirement meaning, not just keywords.
- Identify shared controls and local implementation differences.
- Assign gaps and changes to the relevant owner.
- Preserve review, approval and evidence for each conclusion.
How Sia RegAI supports the workflow
RegReview helps compare controlled regulatory versions and record the source, change, interpretation and applicability decision. RegMatcher connects approved obligations to policies, controls, owners and evidence, surfacing weak or missing mappings for qualified review.
Sia RegAI does not perform customer screening, transaction monitoring or legal interpretation on behalf of the bank. Those decisions and activities remain with the bank’s designated systems and qualified reviewers.
Frequently asked questions
Is HKMA AML-2 part of the Supervisory Policy Manual?
HKMA publishes AML-2 as its Guideline on Anti-Money Laundering and Counter-Financing of Terrorism for Authorized Institutions in the Banking Regulatory Document Repository. Use the current document record rather than an informal module label.
Can one regional AML policy satisfy both jurisdictions?
A group policy can provide a common control standard, but each bank should document how applicable local requirements are implemented and evidenced.
Should the stricter requirement always become the group standard?
Not automatically. A group may choose a higher common standard, but it should assess operational consequences and preserve any jurisdiction-specific legal or procedural requirement.
How often should the comparison be reviewed?
Review it when either regulator changes a relevant source, when associated law or guidance changes, and when the bank materially changes its customers, products, channels, systems or risk profile.
Primary sources
- MAS AML/CFT regulatory resources
- HKMA AML-2 document record and version history
- HKMA AML-2 current guideline PDF listed in the repository
- FATF Recommendations
Informational content only; it is not legal, financial-crime or supervisory advice. Confirm the current official sources before relying on this comparison.