FATF Mutual Evaluation Scorecard

Singapore

Singapore has a developed and inclusive AML/CFT coordination, and has reasonable understanding of its ML risks, based on its NRA. However, gaps are still evident, particularly in inherent risks from transnational threats being one of the world’s largest financial centres.
There is low prosecution and confiscation from foreign predicate ML cases involving shell companies, and a need to put more weight on identifying inherent TF risks.
While financial intelligence uses well-functioning systems and coordination, improvements in utilising such intelligence and information must lead to investigations.
Despite a strong supervision methods, disparity seemingly exists between the supervision and the understanding of ML/TF risks from financial institutions (FIs) and designated non-financial businesses and professions (DNFBPs).
Shortfalls identified on assessing legal persons and arrangements.

AML/CFT supervision under the Monetary Authority of Singapore (MAS) is generally robust, but there were inconsistencies found in the 2014 NRA regarding individual assessments of risks for financial institutions (FIs), and the effectiveness of supervision across agencies and DNFBPs. Furthermore, there were gaps found between preventive measures employed by FIs and DNFPBs. But since then, Singapore has developed into one of the strongest AML/CFT supervisory systems, leading to improved ratings on IO3 and IO4.
With confiscation and prosecution being an opportunity in the 4th MER, Singapore has since made commendable improvements in the said areas, including investigations and convictions, targeting key ML threats both domestic and transnational. Asset recovery also became a high-level political priority driving better ratings for IO8, while improved TF investigations and convictions, reflected in better IO9 scores.
With Singapore growing into an international financial centre and a hub for trade, transportation, and virtual assets, Singapore needs to improve its counter-proliferation financing strategy from being general to risk-proportionate, thus the IO11 downgrade.

Since the 2016 MER and the FURs thereafter, Singapore has made significant investments on technology, data integration and process automation, which has effectively improved financial intelligence and its mitigation and preventive measures, as seen in better ratings for majority of its technical compliance.
Singapore has also risen into a globally significant international financial centre (IFC), and has developed a good understanding of its unique ML/TF risks, backing it with a highly coordinate, well-resourced and mature AML/CFT/CPF regime, and a strong political commitment and will. There had been adaptive and innovative changes to legislation through the years to address opportunities, also leading to improved ratings.
R8 Downgrade: Ultimately, Singapore has evolved into a resilient environment, continuously adapting to its unique and emerging risks as an IFC and due to its geography. Opportunities remain in having sharper and more consistent risk-based results across industries, particularly NPOs, and the constant work required to address cross-border and external threats from illicit financing.