Singapore’s financial ecosystem is governed by one of the most robust anti-money laundering (AML) and countering the financing of terrorism (CFT) frameworks globally. A central pillar of this framework for banks is MAS Notice 626 – “Prevention of Money Laundering and Countering the Financing of Terrorism – Banks”, issued by the Monetary Authority of Singapore (MAS).

This article provides a practical overview of MAS Notice 626, its scope, core requirements, recent updates, and its implications for banks and financial crime compliance professionals.

What Is MAS Notice 626?

MAS Notice 626 sets out the minimum AML/CFT standards that banks operating in Singapore must comply with. It applies to banks licensed, approved, or otherwise authorised under the Singapore Banking Act and aligns closely with the Financial Action Task Force (FATF) Recommendations.

The Notice adopts a risk-based approach, requiring banks to identify, assess, and mitigate money laundering (ML), terrorism financing (TF), and—following recent amendments—proliferation financing (PF) risks in a proportionate manner.

Originally strengthened in 2015, MAS issued an amended version of Notice 626 on 30 June 2025, effective 1 July 2025, reflecting evolving financial crime threats and global regulatory expectations.

Who Does MAS Notice 626 Apply To?

MAS Notice 626 applies specifically to banks operating in Singapore. While other financial institutions such as insurers and payment service providers are governed by separate MAS Notices, banks often interact with fintechs, RegTech firms, and third-party service providers. As a result, understanding bank-level AML/CFT obligations is essential across the broader financial services ecosystem.

Key Requirements Under MAS Notice 626

Risk Assessment
Banks must conduct and document enterprise-wide ML, TF, and PF risk assessments covering customers, products, delivery channels, and geographies. These assessments should be reviewed regularly and updated when risk profiles change.

Customer Due Diligence (CDD) & Beneficial Ownership
Banks are required to identify and verify customers and beneficial owners, understand the purpose of business relationships, and apply enhanced due diligence for higher-risk customers, including politically exposed persons (PEPs).

Ongoing Monitoring & Suspicious Transaction Reporting (STR)
Customer relationships must be monitored continuously to detect unusual or suspicious activity. Suspicious transactions must be reported promptly in accordance with MAS requirements.

Governance, Controls & Audit
MAS Notice 626 emphasises strong internal controls, senior management oversight, independent audits, employee training, and comprehensive record-keeping.

Key Changes in the 2025 Amendments

The 2025 amendments strengthened the regulatory framework by:

• Explicitly incorporating proliferation financing (PF) into AML risk assessments

• Enhancing expectations around source of wealth (SoW) and source of funds (SoF) verification

• Increasing scrutiny of complex ownership structures and third-party funding arrangements

These updates reinforce the need for banks to adopt more sophisticated, data-driven compliance approaches.

Implications for AML Teams and RegTech Providers

MAS Notice 626 has significant implications for how compliance programmes and technology solutions are designed. Banks increasingly rely on integrated systems to support risk-based onboarding, beneficial ownership identification, screening, transaction monitoring, and auditability.

Modern RegTech platforms, such as those offered by ZIGRAM, help financial institutions operationalise these requirements by enabling scalable screening, monitoring, due diligence, and risk assessment aligned with regulatory expectations. Learn more at https://ziqram.com

Conclusion

MAS Notice 626 remains a cornerstone of Singapore’s AML/CFT regulatory regime. With heightened expectations following the 2025 amendments, banks must take a proactive and risk-based approach to compliance. By combining strong governance, trained personnel, and advanced technology, institutions can meet regulatory requirements, mitigate financial crime risks, and maintain trust in Singapore’s globally respected financial system.