MAS Notice 626 — Singapore's AML / CFT rule book for banks.
Issued under the Banking Act, last substantively revised in May 2024. Applies to all banks in Singapore — local, foreign-incorporated, branches. Sets out the obligations on customer due diligence, suspicious-transaction reporting, sanctions screening, and record-keeping that the MAS expects to be operationalised, not papered over.
What the Notice covers
- Risk assessment and risk-based approach — Section 5.
- Customer due diligence (CDD) — Sections 6–7. Identification, verification, beneficial ownership, ongoing monitoring.
- Enhanced due diligence (EDD) — Section 8. Politically exposed persons, higher-risk countries, complex structures.
- Reliance on third parties — Section 9.
- Correspondent banking and wire transfers — Sections 10–13.
- Suspicious-transaction reporting — Section 4 of the CDSA, cross-referenced into Notice 626.
- Sanctions screening — separate notices (e.g. MAS 749 on the sanctions regime), tightly coupled.
- Record-keeping — Section 16. Five years from end of relationship.
- Internal controls, training, audit — Sections 14–15.
The MAS vs HKMA overlap
Roughly 70% of obligations map cleanly between MAS Notice 626 and HKMA's Anti-Money Laundering and Counter-Financing of Terrorism Module. The other 30% is where multi-jurisdictional banks burn budget:
- PEP scope — domestic vs. foreign vs. international-organisation; both regimes define it but the Singapore approach is broader on close associates.
- Beneficial-ownership threshold — both at 25%, but the MAS is more prescriptive on legal-arrangement structures (trusts, foundations).
- STR timing — Singapore uses the "as soon as practicable" standard with internal escalation expectations; Hong Kong uses "as soon as it is reasonable".
- Wire-transfer recordkeeping — sub-thresholds and beneficiary-information requirements differ.
Common findings in real engagements
- CDD documentation refresh cycles slip past the policy-stated frequency.
- BO data captured at onboarding is not refreshed when the legal-arrangement structure changes.
- EDD trigger logic in the case-management system doesn't cover all the MAS Section 8 categories.
- Sanctions screening configured against OFAC and UN but not the EU consolidated list — even where EU exposure is material.
- Internal STR escalation lacks documented rationale for non-filing decisions.
Where Sia RegAI fits
Sia RegAI ingests MAS Notice 626, related MAS Notices (637 capital, 758 wire transfers, 749 sanctions), and the FATF recommendations the MAS aligns to. The obligation tree is normalised across MAS / HKMA / FATF so a regional bank running Singapore and Hong Kong simultaneously sees the differences as a structured diff, not a manual reconciliation.
Related guides
- MAS Notice 626 vs HKMA SPM — side-by-side compliance map
- Regulatory change management software — a buyer's guide
- Automating DORA gap analysis — a practical guide