AML/CFT Audit Singapore | Compliant with AML/CFT Requirements | Professional | Streamlined | MAS-Compliant Audit Reports

With over 15 years of experience in Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT), we offer a Singapore AML/CFT audit solution to financial institutions (FIs), designated non-financial businesses and professions (DNFBPs) and other types of Singapore-based AML/CFT reporting entities helping them comply with local AML/CFT requirements, including requirements to undergo an AML/CFT audit compliant with:

 

Singaporean AML/CFT Audit Standards, including

 

Singaporean AML/CFT laws and regulations, including:

  • Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (CDSA)
  • Terrorism (Suppression of Financing) Act (TSOFA)
  • Payment Services Act (PSA)
  • Monetary Authority of Singapore (MAS) AML/CFT Notices (e.g., Notice 626 for banks, Notice PSN01 for payment service providers)

 

MAS Guidelines and Independent AML/CFT Audit Requirements

If you search for Singaporean AML/CFT auditors online, everyone claims to be an expert, uses puffery language that AI chatbots write for them, and so on and so forth.

We are not just another AML/CFT audit provider firm that claims to have extensive knowledge of Singaporean AML compliance.

We are the ones who know what we are doing, having years of experience in all aspects of AML/CFT compliance, including:

  • Creating and successfully enhancing anti-money laundering and counter-terrorist financing frameworks for different businesses tailored to their specific product, resources, risk appetites and sector-specific money laundering and terrorism financing (ML/TF) risks
  • Conducting AML/CFT risk assessments through a wide range of FIs and DNFBPs
  • Handling the first, second, and third lines of AML/CFT compliance and management.
  • Acting as external AML/CFT auditors for FIs and DNFBPs
  • Conducting internal AML/CFT audits that go beyond statutory requirements
  • Successfully assisting businesses in going through statutory AML/CFT reviews, including those conducted by the top four. We know a thing or two about good and bad AML auditors
  • Helping FIs and DNFBPs when things go wrong, including coordinating their risk and compliance teams, legal teams, external lawyers, and operations teams
  • Helping businesses with MAS reviews
  • Helping a variety of FIs and DNFBPs with their AML/CFT remediation

We have the necessary expertise to complete AML/CFT independent reviews and know what businesses want from their AML/CFT auditors.

 

Singaporean AML/CFT Audit Solutions’ Scope

Our Singaporean AML/CFT audit solution is tailored for different types of FIs and DNFBPs, including but not limited to:

  • Investment bankers
  • Investment firms
  • Fund managers
  • Brokers, including forex brokers
  • Fintech companies
  • Non-bank Deposit takers
  • Non-bank lenders
  • Online casinos and gambling platforms
  • Currency exchange providers
  • E-money issuers
  • Money remitters
  • Payment gateway providers
  • Derivatives issuers and platforms
  • Neo-banks
  • P2P lending platforms
  • Crowdfunding services and platforms
  • Financial advisers
  • Investment advisers
  • Wealth managers
  • Custodial or depository service providers
  • Consumer credit providers
  • Credit unions
  • Corporate finance providers
  • Finance companies
  • Designated non-financial businesses and professions (DNFBPs), including trust and company formation providers (TCSPs)

 

Singapore AML/CFT Audit Focus

We cover Singaporean AML/CFT audit requirements as outlined by Singapore legislation (CDSA, TSOFA, PSA), MAS guidance and accepted AML/CFT audit practices. Our focus areas include, but are not limited to:

  • AML/CFT Enterprise-Wide Risk Assessment (EWRA) Audit, including a review of:
    • Whether it identifies the risks faced by your business
    • Whether there are checks in place to ensure it is up to date
    • Whether it enables you to determine the level of risk involved in relation to various AML/CFT obligations. We cover the five key ML/TF risk areas: products, size and complexity, delivery channels, the countries you engage with, and the institutions you deal with
    • Whether it is based on the local AML/CFT laws and guidance materials produced by MAS
  • AML/CFT Program Audit, including a review of:
    • Whether your AML/CFT Program is functioning in practice as intended
    • Whether it complies with the requirements outlined in the applicable AML/CFT laws and regulations
    • Whether there is a governance structure or committee overseeing AML/CFT matters, including a mechanism to escalate issues (e.g., high-risk customer onboarding, suspicious transaction reporting) to senior management or the board
  • Whether you comply with your obligations under the Singaporean AML/CT requirements, including, but not limited to:
    • Initial customer due diligence requirements, including simple, standard, and enhanced due diligence
    • Screening
    • Beneficial ownership identification
    • Record-keeping
    • Customer risk rating
    • Ongoing customer due diligence
    • Transaction monitoring, covering the detection and handling of large, unusual, and suspicious transactions and patterns
    • Wire transfers (e.g., ensuring that the bank or FI screens the remitting/receiving parties, timely disposition of potential hits, and appropriate escalation)
    • Reporting timeliness and accuracy
    • Governance and oversight
    • Staff vetting and training
    • Obligations covering the detection, escalation, and reporting of suspicious activities and suspicious transactions (STRs), along with other statutory reporting obligations, etc.
  • AML/CFT Framework Application review, including the following areas:
    • Whether the policies, procedures, and controls based on your EWRA have been adequately designed and operate effectively
    • Conducting limited assurance testing of AML/CFT controls, including but not limited to CDD, ODD, and transaction monitoring, recordkeeping, etc.
    • Verifying the operational effectiveness of reporting systems
    • Assessing the extent to which employees understand and comply with your AML/CFT Program
    • The implementation of your AML/CFT Program or equivalent arrangements by branches, and outsourced providers
    • Reviewing how any previously identified deficiencies or non-compliance areas have been addressed
    • Assessing the adequacy of your AML/CFT employee training Program
    • Reviewing the approach to transaction monitoring scenario setting, parameters, and threshold calibration for ongoing effectiveness

 

Singaporean AML/CFT Audit Methodology

We can select and apply an appropriate methodology that works for your business or conduct an AML/CFT review using your audit methodology.

 

Singaporean AML Reviews Frequency

The frequency of AML/CFT audits in Singapore depends on:

  • Your business size
  • Your products
  • The complexity of the business
  • Your ML/TF risk levels

In terms of AML/CFT obligations in Singapore, this is between one and three years for organisations with higher ML/TF risk. Also, MAS may require a business to conduct an AML/CFT audit.

 

MAS AML Compliance and Triggers for Independent AML Review

A requirement for an AML/CFT Audit in Singapore may be triggered by a number of factors, including:

  • Structural changes to your business
  • Changes to the ML/TF risk of your business
  • Changes in fund deposit or withdrawal methods
  • Changes in outsourcing arrangements for ML/TF prevention functions
  • Substantial changes to the AML/CFT Program
  • Changes to the number or volume of transactions
  • Substantial changes in markets of operations and customer types
  • Introduction of new products
  • Substantial updates in Singaporean AML/CFT requirements, MAS Notices or industry-specific regulations that impact AML/CFT compliance framework of an organisation
  • Changes in delivery methods for your services
  • AML/CFT remediation issues faced/completed by the business

 

Singaporean AML Audit Requirements and Independent Review Report

We issue detailed AML/CFT audit reports with findings and actionable recommendations. These reports outline:

  • What was tested during the review
  • The methodologies used in conducting the tests
  • The sample sizes applied in the testing process

Our reports are designed to provide senior management and, where applicable, the governing board with clear insights into compliance performance.

 

Singaporean AML Audit Program & Audit Stages

Singaporean AML Audit process generally involves:

  • Initial Meeting & Scope Definition:
  • Defining the scope and objectives of the audit with the FI or a DNFBP
  • Understanding the entity's business, risk profile, and existing AML/CFT program
  • Documentation Review:  Reviewing key AML/CFT documents
  • Sampling & Testing: Performing sampling and testing of compliance with the Singaporean AML/CT requirements and AML/CFT program. Examples include:
  • Testing CDD procedures (customer identification & verification).
  • Reviewing transaction monitoring alerts and SAR investigations.
  • Assessing the effectiveness of the ML/TF Risk Assessment process.
  • AML/CFT controls testing (if applicable)
  • Interviews & Inquiries:
  •  Interviewing key personnel (compliance officers, management, front-line staff)
  • Accessing implementation of your processes
  • Application of Audit Methodology:
  • Applying appropriate audit methodologies, such as risk-based auditing, to assess the effectiveness of the AML/CFT program
  • Report Preparation & Presentation:
  • Preparing a comprehensive audit report
  • Presenting findings, conclusions, and recommendations to management

 

AML/CFT Audit and Information Sampling

FIs and DNFBPs focus on evaluating how effectively an organisation complies with its obligations under the Singaporean AML/CT requirements and its AML/CFT program. Independent audits typically involve reviewing samples of:

  • Individual customers, including resident and non-resident clients, various types of corporate clients (e.g., limited liability companies, limited partnerships, and entities with complex beneficial ownership structures), as well as trusts and investment vehicles
  • Customers presenting different ML/TF risks, including those categorised as medium- or high-risk
  • Large, complex, or unusual transactions to determine how effectively the entity meets its transaction monitoring obligations
  • Ad-hoc and periodic reports on customer transactions and activities, such as Suspicious Transaction Reports (STRs), to assess compliance with reporting obligations.
  • AML/CFT training and staff vetting records
  • Specialised client and transactional registers (e.g., high-risk clients, politically exposed persons (PEP) registers, etc.)
  • Materials aimed at enhancing ML/TF risk awareness and operational compliance
  • Records maintained for specific clients or/and transactions to verify compliance with record-keeping obligations under the Act

 

Singaporean Independent AML Review Solutions Tailored to Your Needs

When it comes to delivery, we:

  • Focus on clear, concise, and objective assessments. No ego, no attitude, no puffery, and no jargon
  • Have real knowledge of AML/CFT compliance and how each aspect works
  • Use a client-centric approach. We understand the difference between your risk appetite, internal procedures, and AML/CFT requirements
  • Cause minimal interruptions to your business (combining onsite and remote engagements)
  • Provide comprehensive audit reporting compliant with MAS and industry expectations

When it comes to flexibility, we:

  • Offer realistic pricing options
  • Tailor our approach to your specific needs and risk profile, offering limited assurance, reasonable assurance, and holistic options. We offer AML audit solutions to:
  • Small businesses and startups
  • Mid-sized businesses
  • Business groups, including those with centralised compliance functions across subsidiaries, those operating across different compliance regimes, and offering a range of products
  • High-risk corporates that come under regulatory scrutiny and pressure from important stakeholders, such as banking partners, insurance providers, and money remittance channels

 

Independent AML Review Preparation 

We offer a comprehensive Internal AML Review Solution with the following features:

  • Deeper Audit Focus, including:
  • Evaluating the effectiveness of your AML/CFT compliance against your business goals, future objectives, wider risk appetite, and more
  • Deep diving into the effectiveness of AML/CFT controls
  • Covering specific review areas such as AML technology, process optimisation, and more.
  • Flexible Scope: Designed with a flexible audit scope, which can be customised to your needs, as opposed to the Independent AML Review under the Singaporean AML/CFT requirements
  • External Audit Preparation: Focused on internal improvement and identifying issues before external scrutiny, helping you prepare for an independent AML review, an enhanced review by a banking partner
  • Regulatory review Preparation: Focused on preparing you for a review by MAS covering an assessment of MAS' recent inspection trends and common non-compliance findings in your sector
  • Non-binding findings: The audit report is confidential, giving you the opportunity to address any identified issues discreetly
  • More information: Visit our Internal AML Review Solution page for more information

 

Related AML/CFT Solutions

In addition to our Singaporean AML audit option, we offer a comprehensive set of AML/CFT compliance solutions, helping you navigate the complexities of Singaporean AML requirements in a commercially oriented and goal-focused manner, providing effective support for all aspects of the anti-money laundering compliance. Our focus areas include but are not limited to:

  • AML/CFT Advisory: We provide advisory solutions on a wide range of AML/CFT matters and issues. Visit our AML/CFT Advisory page for more.
  • AML/CFT Compliance Management: We can fully manage your anti-money laundering and terrorist financing compliance. Visit our AML/CFT Compliance Management page for more.
  • AML/CFT Enterprise-Wide Risk Assessments: We conduct, review, and help businesses implement AML/CFT Risk Assessments that form the foundation of effective AML/CFT Programs. Visit our AML/CFT Risk Assessment page for more.
  • AML/CFT Programs: We draft, review, and help businesses implement AML/CFT Program based on the ML/TF risk assessment outcomes. Visit our AML/CFT Program page for more.
  • AML/CFT Reg-tech Solutions: We help with AML/CFT technology integration tailored to your circumstances, including tools to help you with data analytics (“DA”) to automate ML/TF risk-scoring and streamline ODD processes.
  • AML/CFT Training: We offer specialised AML/CFT training solutions for different FIs and DNFBPs. Visit our AML/CFT Training page for more.
  • AML/CFT Procedures: We assist in developing and enhancing AML/CFT procedures tailored to your business needs, focusing on effective AML risk management across business processes.
  • AML Manuals and Guidelines: We create and refine practical resources such as AML operating manuals and guidelines that provide step-by-step instructions to ensure efficient AML/CFT compliance based on your business size and complexity
  • ML/TF Controls Mapping: We help map, assess, and enhance internal ML/TF controls to ensure compliance, address financial crime risks, and respond to findings from AML/CFT audits and supervisors.
  • AML Red Flag Protocols: We develop guidelines for identifying and responding to red flags, enabling timely action against fraud, money laundering, and terrorist financing activities under various operational circumstances.