新加坡（四）：反洗钱/打击资助恐怖主义与合规——Alexander Ressos博士著作《新加坡与瑞士数字资产法》（Digital Assets Law in Singapore and Switzerland）的一部分。
新加坡（四）：反洗钱/打击资助恐怖主义与合规：Alexander Ressos博士著作《新加坡与瑞士数字资产法》（Digital Assets Law in Singapore and Switzerland）的一部分。
本部分属于Alexander Ressos博士的著作新加坡与瑞士数字资产法，全书在本站逐节完整发布。
新加坡之四：反洗钱/反恐怖融资与合规
Anti-money-laundering law is the part of Singapore's digital-asset regime that decides whether a business survives contact with its own customers. Read more Singapore · AML and Sanctions三部法令与一个监管机构
Singapore's AML/CFT regime rests on three statutes, each of which does a different job. Read more Singapore · AML and SanctionsMAS通告：PSN01、PSN02与DTSP通告
The operational AML/CFT duties of a DPT business are set out in MAS notices issued under the PSA. Read more Singapore · AML and SanctionsFATF层面
Singapore has been a member of the Financial Action Task Force (FATF) since 1992 and held the FATF Presidency from July 2022 to June 2024 through T. Raja Kumar. Read more Singapore · AML and Sanctions国家风险评估与数字资产行业风险
Singapore published its first money-laundering national risk assessment in January 2014 and its first terrorism-financing assessment in 2020. Read more Singapore · AML and Sanctions从整体上理解这一制度
The compliance officer of a Singapore DPT firm works with five layers at once. The criminal statutes set the offences and the personal exposure. The MAS notice sets the duties. Read more Singapore · AML and SanctionsPSN02的结构
MAS Notice PSN02 is organised in the same sequence as every other MAS AML/CFT notice, from the Banking Act notice (MAS Notice 626) to the notices for capital markets intermediaries, trust companies… Read more Singapore · AML and Sanctions全企业风险评估
Before any customer is onboarded, PSN02 requires the firm to identify and assess the money-laundering and terrorism-financing risks it faces across customers, countries, products, services,… Read more Singapore · AML and Sanctions标准CDD：识别、核实与目的
The core of PSN02 is the duty to identify the customer, to verify that identity using reliable and independent sources and to identify and take reasonable measures to verify the beneficial owner. Read more Singapore · AML and Sanctions简化CDD
PSN02 allows simplified CDD where the firm has assessed the risk of a customer, product or transaction as low, provided the assessment is documented and consistent with the enterprise-wide risk… Read more Singapore · AML and Sanctions强化CDD
Enhanced CDD is mandatory for three categories and discretionary for a fourth. Read more Singapore · AML and Sanctions筛查
PSN02 requires the firm to screen customers, natural persons appointed to act, connected parties and beneficial owners against relevant lists at onboarding, on a periodic basis and when lists are… Read more Singapore · AML and Sanctions持续监控
CDD is not complete at onboarding. Read more Singapore · AML and Sanctions依赖第三方
PSN02 permits a firm to rely on a third party to perform the identification, verification and purpose elements of CDD. Three conditions apply. Read more Singapore · AML and Sanctions记录保存与个人数据
Records of CDD, account files, business correspondence and transaction data must be kept for at least five years after the end of the business relationship or the completion of the occasional… Read more Singapore · AML and Sanctions起源与目的
The travel rule is the requirement that information about the originator and the beneficiary of a transfer accompany the transfer itself, so that each institution in the chain and any investigator… Read more Singapore · AML and Sanctions新加坡规则：PSN02关于价值转移的规定
PSN02 applies the value-transfer requirements to every DPT transfer that a licensee makes or receives on behalf of a customer, whatever the amount. The information set depends on value. Read more Singapore · AML and Sanctions非托管钱包
The hardest case is the transfer to or from a wallet whose keys are held by a private person without any institution behind it. The FATF calls these "unhosted" or "self-hosted" wallets. Read more Singapore · AML and Sanctions对手方尽职调查
The travel rule only works if the firm knows which institution stands behind the beneficiary address. Read more Singapore · AML and Sanctions“日出”问题
The FATF borrowed the "sunrise" image to describe the period during which the travel rule has dawned in some jurisdictions and not in others. Read more Singapore · AML and Sanctions不完整及不合规的转账
A Singapore licensee that receives a DPT transfer lacking the required information has three lawful responses: execute and follow up, suspend pending information, or reject and return. Read more Singapore · AML and Sanctions旅行规则中的数据保护
Transmitting a customer's name, address and identification number to a foreign institution is a cross-border transfer of personal data. Read more Singapore · AML and Sanctions旅行规则的发展方向
Three developments were visible at the state-of-law date. Read more Singapore · AML and Sanctions法定报告义务
The duty to report sits in s. 45 of the CDSA and binds every person in Singapore, whether or not they are regulated. Read more Singapore · AML and SanctionsPSN02的叠加要求
For a DPT licensee the statutory duty is supplemented by PSN02. Read more Singapore · AML and Sanctions形成怀疑：数字支付代币的典型模式
What makes a DPT transaction suspicious? Read more Singapore · AML and Sanctions报告的时效与质量
The statute says "as soon as is reasonably practicable". Read more Singapore · AML and Sanctions提交报告之后
Filing an STR does not end the firm's obligations or its exposure. Four questions arise. Read more Singapore · AML and Sanctions律师的处境
Lawyers in Singapore are not exempt from s. 45. The duty applies to knowledge acquired in the course of a profession, of which the profession of law is no exception. Read more Singapore · AML and Sanctions集团内部的报告
Where a Singapore DPT licensee is part of a group, the firm must decide how much of an STR may be shared with affiliates. Read more Singapore · AML and Sanctions为何一宗案件独占一章
On 15 August 2023 some four hundred officers of the Singapore Police Force conducted simultaneous raids across the island and arrested ten foreign nationals on charges of money laundering, forgery… Read more Singapore · AML and Sanctions案件事实
The ten accused, nine men and one woman, were born in Fujian province in China and had acquired the citizenship of other countries, among them Cambodia, Cyprus, Vanuatu, Turkey, Dominica and Saint… Read more Singapore · AML and Sanctions问题出在哪里
The Inter-Ministerial Committee established in October 2023 to review the case published its report on 4 October 2024. Read more Singapore · AML and Sanctions政策应对
The response came in four waves between late 2023 and mid-2025. Read more Singapore · AML and Sanctions加密资产层面
The case was not a crypto case in the sense that the public assets were mostly real estate and bank balances. Its lessons for the digital-asset sector are nonetheless direct. Read more Singapore · AML and Sanctions数字支付代币持牌机构应从该案中汲取的教训
The committee's report and the 2025 penalties define the standard that MAS now applies to every supervised institution, including DPT licensees. Six points translate directly. Read more Singapore · AML and Sanctions比较视野下的该案
Switzerland has had its own formative cases, from the Abacha and Montesinos funds to 1MDB and Petrobras, and has reacted in each instance with a tightening of due-diligence rules, the most recent… Read more Singapore · AML and Sanctions新加坡的制裁立场
Singapore's sanctions policy differs from Switzerland's in a way that a dual-hub compliance programme must take into account from the first day. Read more Singapore · AML and Sanctions联合国制裁：法律机制
The United Nations Act 2001 empowers the Minister to make regulations to give effect to decisions of the United Nations Security Council under Article 41 of the Charter. Read more Singapore · AML and Sanctions2022年3月的对俄措施
On 5 March 2022 Singapore announced sanctions against Russia in response to the invasion of Ukraine, acting for the first time in decades without a Security Council mandate. Read more Singapore · AML and SanctionsOFAC与商业现实
No Singapore law requires a Singapore DPT licensee to comply with United States sanctions administered by the Office of Foreign Assets Control (OFAC). Read more Singapore · AML and Sanctions数字支付代币持牌机构的筛查实务
Sanctions screening at a DPT licensee has three components that a fiat institution's screening lacks or has in simpler form. Read more Singapore · AML and Sanctions扩散融资
The FATF added a proliferation-financing risk-assessment requirement to Recommendation 1 in October 2020. Read more Singapore · AML and Sanctions制裁与律师
A lawyer advising a DPT licensee on sanctions in Singapore must hold three jurisdictions in view at once. The Singapore layer determines what is unlawful and what must be frozen and reported. Read more Singapore · AML and SanctionsMAS所期望的治理架构
PSN02 closes with the requirements that make everything before it work: internal policies, procedures and controls approved by senior management, a compliance function with adequate resources and… Read more Singapore · AML and Sanctions合规官
PSN02 requires the appointment of an AML/CFT compliance officer at management level, with sufficient resources, independence and access to information to perform the role. Read more Singapore · AML and Sanctions技术风险与网络卫生
A DPT licensee's AML/CFT controls run on technology, and MAS regulates that technology through two notices and one set of guidelines that are in practice inseparable from the AML programme. Read more Singapore · AML and Sanctions外包与第三方风险
Most DPT licensees outsource core parts of their compliance stack: identity verification, sanctions screening, transaction monitoring, blockchain analytics and travel-rule messaging are all… Read more Singapore · AML and Sanctions独立审计
PSN02 requires an independent audit function to assess the adequacy and effectiveness of the AML/CFT programme regularly. Read more Singapore · AML and SanctionsMAS检查
MAS supervises DPT licensees through off-site monitoring of returns and STR copies, through thematic reviews across groups of licensees and through on-site inspections of individual firms. Read more Singapore · AML and Sanctions针对数字支付代币持牌机构的执法
MAS's enforcement toolkit under the PSA and the FSMA comprises supervisory directions, licence conditions, composition of offences and reprimands. Read more Singapore · AML and Sanctions员工培训、筛查与合规文化
PSN02 requires the firm to screen employees for integrity before hiring and to train them on AML/CFT at induction and regularly thereafter, with content tailored to their roles. Read more Singapore · AML and Sanctions问题的提出
The typical client of a Swiss–Singapore digital-asset practice is a group. Read more Singapore · AML and Sanctions集团计划的法律依据
Both regimes require or assume a group-wide approach, but with different reach. Read more Singapore · AML and Sanctions两种制度的分歧所在
The following table sets out the points at which a group cannot apply one rule to both entities without choosing. Read more Singapore · AML and Sanctions实体之间的依赖
The most common operational question is whether one entity may rely on the CDD performed by the other, so that a customer onboarded in Zug can open an account in Singapore without repeating the… Read more Singapore · AML and Sanctions由哪个实体服务哪类客户
Reliance solves the onboarding question but not the structural one: which entity should have the customer relationship at all? Three rules of thumb have emerged. Read more Singapore · AML and Sanctions信息共享及其限制
A group programme depends on the two entities knowing what each other knows about shared customers. Four legal constraints shape what may be shared. Read more Singapore · AML and Sanctions集团协议范本
The following elements constitute a group AML protocol that in my experience satisfies both regulators. Read more Singapore · AML and Sanctions拥有新加坡MPI的瑞士SRO成员：三个反复出现的问题
Three questions arise so often in this configuration that they deserve direct answers. Read more