KEY TAKEAWAYS
- Singapore has introduced new AML/CFT regulations for Market Operators, while the UAE continues to enforce a broader framework covering financial institutions, DNFBPs, and VASPs.
- Both jurisdictions mandate strict Customer Due Diligence, requiring identity verification, risk assessments, and enhanced due diligence for high-risk clients.
- Ongoing transaction monitoring and record-keeping are key compliance requirements, with a minimum five-year retention period.
- Suspicious Transaction Reporting is mandatory, ensuring timely detection and reporting of potential financial crimes to MAS (Singapore) and FIU (UAE).
- These measures reinforce market integrity and global AML/CFT leadership, positioning Singapore and the UAE as benchmarks for regulatory excellence.
INTRODUCTION
As the global financial ecosystem evolves, so do the threats posed by money laundering ("ML") and terrorist financing ("TF"). In response, regulators worldwide are continuously refining their anti-money laundering ("AML") and countering the financing of terrorism ("CFT") frameworks to safeguard financial markets and maintain financial integrity.
Among the jurisdictions leading this regulatory evolution are the United Arab Emirates ("UAE") and Singapore—both of which have implemented robust AML/CFT measures that balance stringent compliance requirements with fostering a competitive, innovation-driven economy.
Singapore strengthened its regulatory stance in January 2025 by introducing new AML/CFT requirements1 for Approved Exchanges2 and Recognised Market Operators ("Market Operators"),3 underscoring its commitment to mitigating financial crime risks. Meanwhile, with its well-established and comprehensive AML/CFT legal framework, the UAE continues to enforce strict regulatory measures to detect, prevent, and combat illicit financial activities.
This article explores both jurisdictions' AML/CFT regulatory landscapes, examining key requirements, enforcement mechanisms, and their implications for financial institutions and market participants.
SINGAPORE'S NEW AML/CFT FRAMEWORK: STRENGTHENING MARKET INTEGRITY
Singapore continues to strengthen its financial crime prevention measures with the latest AML/CFT regulations issued by the Monetary Authority of Singapore ("MAS"). The updated MAS AML/CFT Notice, applicable to Market Operators, enhances regulatory oversight over non-financial institution ("non-FI") participants who directly engage in trade-related activities on organised markets. This initiative aims to mitigate the risks associated with unregulated entities, reinforcing Singapore's commitment to upholding market integrity and aligning with international AML/CFT standards.
Key Features of MAS's AML/CFT Notice
- Enhanced AML/CFT Obligations
Market Operators must now implement comprehensive due diligence procedures for non-FI participants, a category that was previously outside the regulatory purview. This change addresses the heightened ML and TF risks posed by direct market access.4
- Robust Customer Due Diligence Measures
Market Operators are required to assess and manage ML/TF risks before engaging in business relations. The Customer Due Diligence ("CDD") framework mandates:
- Identity Verification: Establishing and verifying customer identities, including beneficial owners.5
- Business Assessment: Understanding the customer's nature of business, typical transaction behaviour, and risk profile.6
- Enhanced Scrutiny for High-Risk Clients: Implementing additional checks for politically exposed persons and customers from high-risk jurisdictions.7
CDD measures must be implemented when establishing a business relationship, when undertaking a transaction exceeding SGD 20,000, when undertaking a digital capital markets product token, or when there is suspicion of money laundering or terrorism financing.8
- Continuous Monitoring & Record-Keeping
Market Operators must actively track customer transactions, flagging any suspicious activity that deviates from expected business behaviour.9 Additionally, records must be securely maintained for at least five years to support audits and regulatory reviews.10
- Mandatory Suspicious Transaction Reporting
Operators are required to promptly report any irregular transactions and financial activities to the Suspicious Transaction Reporting Office, ensuring accountability and transparency in financial transactions.11
- Strengthened Internal Controls & Compliance Measures
To ensure compliance, Market Operators must establish robust internal policies aligned with AML/CFT requirements, appoint dedicated compliance officers to oversee regulatory adherence and implement regular training programs to equip employees with the knowledge and skills to detect and prevent financial crimes effectively.12
Singapore's proactive approach to AML/CFT regulation reinforces its reputation as a secure and well-regulated financial hub, strengthening confidence among market participants and investors worldwide.
UAE'S AML/CFT FRAMEWORK: A LEGACY OF STRINGENT REGULATION
The UAE has long been at the forefront of AML/CFT enforcement, with a regulatory framework rooted in Federal Decree-Law No. 20 of 2018 (as amended by Federal Decree-Law No. 26 of 2021) and its accompanying Cabinet Decisions. These laws set forth comprehensive requirements for financial institutions and designated non-financial businesses and professions ("DNFBPs"), reinforcing the nation's commitment to combatting illicit financial activities.
Key Aspects of UAE's AML/CFT Regulations
- Customer Due Diligence:
Identity Verification: Financial institutions must collect extensive information on both individuals (e.g., official name, nationality, address, employer details) and legal entities (e.g., legal form, memorandum of association, senior administration details).
Risk-Based Approach: Entities must assess ML/TF risks using a multi-faceted approach that considers customer profiles, geographic locations, product types, and transaction channels.
- Enhanced Due Diligence for High-Risk Clients:
Customers from high-risk jurisdictions or engaging in complex financial activities are subject to heightened scrutiny.
Institutions must gather additional information on beneficial ownership structures, sources of wealth, and transactional behaviours.
Senior management approval is required before establishing relationships with high-risk clients.
- Ongoing Monitoring & Beneficial Ownership Transparency:
Transactions must be continuously monitored to detect suspicious activities, ensuring alignment with a customer's known financial behaviour.
Legal entities must disclose and verify their beneficial owners (holding 25% or more of controlling stakes) through independent, verifiable sources.
- Record-Keeping Obligations:
All financial transaction records, including customer data and KYC documentation, must be retained for a minimum of five years.
- Reporting Obligations:
- Suspicious Transaction Reports: Entities must file Suspicious Transaction Reports promptly upon identifying potentially illicit activities, with an expedited 24-hour reporting requirement for high-risk cases.
- Large Transaction Reports: While no fixed reporting threshold exists, transactions exceeding AED 55,000 or wire transfers above AED 3,500 must undergo thorough CDD measures.
- FATF's Travel Rule Compliance: Institutions must ensure that all international wire transfers above AED 3,500 contain complete sender and beneficiary details.
SINGAPORE VS. UAE: A COMPARATIVE OVERVIEW
CONCLUSION
Both the UAE and Singapore have demonstrated a strong commitment to AML/CFT excellence, albeit through distinct regulatory approaches. While Singapore's new AML/CFT Notice implements targeted measures specifically for Market Operators, the UAE's framework adopts a more comprehensive scope, extending to financial institutions, DNFBPs, and virtual asset service providers.
For businesses operating in these jurisdictions, adherence to these stringent regulations is not only a legal obligation but also a strategic necessity to uphold market integrity and mitigate financial crime risks. As global AML/CFT standards continue to evolve, both the UAE and Singapore serve as exemplary models of regulatory innovation and financial security, setting benchmarks for other jurisdictions to follow.
Footnotes
2 Section 2 of the Securities and Futures Act 2001.
3 Section 2 of the Securities and Futures Act 2001.
4 Paragraph 3, MAS Notice SFA02-N05.
5 Paragraph 6, MAS Notice SFA02-N05.
6 Paragraph 6(VI), MAS Notice SFA02-N05.
7 Paragraph 8, MAS Notice SFA02-N05.
8 Paragraph 6.3, MAS Notice SFA02-N05.
9 Paragraph 6(VI), MAS Notice SFA02-N05.
10 Paragraph 10, MAS Notice SFA02-N05.
11 Paragraph 12, MAS Notice SFA02-N05.
12 Paragraph 13, MAS Notice SFA02-N05.
14 Available at https://rulebook.centralbank.ae/en/rulebook/decree-federal-law-no-20-2018-anti-money-laundering-and-combating-financing-terrorism-and.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
