Global Digital Finance (GDF) & Web3 Harbour (W3H) convened their joint APAC Policy and Regulatory Working Group to analyse the Monetary Authority of Singapore (MAS) Consultation Paper on Proposed Amendments to AML/CFT Notices and Guidelines. Through this process we identified two thematic areas for MAS’s consideration. The key themes identified are:
1. We support the amendments with regards to proliferation financing (PF) and TCA-N03 and their alignment to FATF’s guidance; and
2. We believe it would be beneficial for MAS to provide some additional guidance around STR filings – particularly for clearly defining the phrases “suspicion first established” and “exceptional circumstances”.