Singapore's Monetary Authority of Singapore (MAS) has issued updated AML directives that take effect from July 1, 2025. International companies operating in or through Singapore now face tightened obligations around customer due diligence, beneficial owner disclosure, and internal controls. Failing to act before the deadline exposes businesses to licence suspension, civil penalties, and reputational damage that can close off access to correspondent banking relationships.
The 2025 AML updates in Singapore introduce stricter know-your-customer (KYC) requirements, mandatory beneficial owner verification at enhanced thresholds, and expanded reporting duties for designated financial institutions and corporate service providers. Companies must align internal policies with the revised MAS guidelines and complete a gap assessment before the July 1, 2025 effective date. Businesses that fail to comply face regulatory enforcement by MAS and potential referral to the Singapore High Court for civil or criminal proceedings.
This alert covers which business categories are affected, the specific threshold criteria that trigger enhanced obligations, and five immediate actions your organisation should take now.
What has changed and when it takes effect
MAS issued the revised AML guidelines in the first quarter of 2025. The changes take effect on July 1, 2025 and apply immediately to newly onboarded clients. Existing client relationships must be brought into conformity within 90 days of that date – no later than September 29, 2025.
The core change is a recalibration of the beneficial owner threshold under Singapore's anti-money laundering legislation. The previous ownership threshold for triggering enhanced due diligence has been lowered. Any individual holding or controlling a material interest in a corporate customer is now subject to full KYC verification. MAS has also expanded the definition of a politically exposed person and aligned it with the Financial Action Task Force (FATF) revised standards published in 2023.
A second material change relates to correspondent banking. Regulated institutions must now conduct periodic reassessments – not just onboarding checks – of every correspondent banking relationship. The reassessment cycle must be documented and retained for a minimum period prescribed under Singapore's banking legislation.
The Accounting and Corporate Regulatory Authority (ACRA) has simultaneously updated its register of beneficial owners under corporate legislation applicable to Singapore-incorporated entities. Companies registered under the Companies Act Singapore must ensure their nominee and shareholder structures accurately reflect the updated beneficial owner definitions. Any discrepancy between the ACRA register and the information held by a financial institution creates a compliance gap that MAS treats as a red flag during inspections.
Who is affected and what the thresholds require
The updated obligations apply to three broad categories of business operating in Singapore.
First, MAS-licensed financial institutions – including banks, finance companies, and capital markets intermediaries. These entities face the strictest obligations. They must update their AML and KYC policies, retrain compliance staff, and document the updated procedures in board-approved frameworks before July 1, 2025.
Second, corporate service providers and registered filing agents operating under ACRA supervision. These entities assist clients with company formation, nominee directorship arrangements, and registered address services. Under the revised rules, they are now treated as obligated entities for AML purposes. This is a significant extension of scope that many smaller service providers have not yet addressed.
Third, multinational companies that maintain Singapore subsidiaries and use local entities to access credit facilities or to structure regional treasury operations. Although not themselves regulated financial institutions, these companies are indirectly affected because their Singapore bankers will now apply the enhanced due diligence standards at each review cycle. A company that cannot produce up-to-date beneficial owner information risks losing access to its credit facility or having its bank account opening request refused or revoked.
The enhanced due diligence threshold is triggered when any of the following conditions are present: the customer operates in a sector identified by MAS as higher-risk. the transaction involves a jurisdiction on the FATF grey or black list. the beneficial owner structure involves nominee arrangements or trust layers. or the customer is seeking a credit facility above a prescribed monetary band.
For a practical assessment of how these thresholds interact with your Singapore banking and capital markets activities, see our analysis of banking and finance law in Singapore.
To discuss how the updated AML rules affect your Singapore entity's access to credit facilities or banking relationships, contact us at info@ferrazwhitmore.com.
Immediate actions for international companies
The following five steps address the most common compliance gaps identified among international businesses with Singapore operations.
Step 1 – Audit your beneficial owner records. Verify that the information held by your bank, your corporate service provider, and the ACRA register is consistent and current. Any individual who holds or controls a material interest must be identified with full KYC documentation. Outdated records are the single most common trigger for enforcement action by MAS.
Step 2 – Review nominee and trust structures. If your Singapore entity uses nominee shareholders or directors, confirm that the underlying beneficial owner is properly disclosed. MAS and ACRA treat undisclosed nominees as a priority risk indicator. This applies equally to shelf companies and newly incorporated entities.
Step 3 – Map your correspondent banking exposure. If your operations rely on international payments routed through Singapore correspondent banks, identify which relationships are subject to the new periodic reassessment obligation. Reassessment requests from your Singapore bank may arrive with short notice. Preparing the required documentation in advance avoids disruption to payment flows.
Step 4 – Update internal AML policies. Board-approved AML and KYC policies must reflect the revised MAS definitions. Policies that reference the pre-2025 thresholds are non-compliant as of July 1, 2025. Compliance officers should conduct a line-by-line gap analysis against the updated MAS guidelines and present the results to the board before the effective date.
Step 5 – Brief your senior management and board. MAS places individual accountability obligations on senior managers of regulated entities. The Singapore High Court has in previous enforcement actions confirmed that personal liability can attach to officers who fail to implement adequate AML controls. Board minutes should record that the 2025 updates were reviewed and that remediation steps were approved.
International companies with exposure to capital markets activity in Singapore should also review the related obligations addressed in our overview of capital markets regulation in Singapore.
Companies navigating similar AML developments in other jurisdictions may find useful context in our alert on AML updates in the UAE.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our team combines Portuguese civil law expertise with English common law tradition to deliver cross-border legal solutions in banking and finance regulation, AML compliance, and corporate governance. We advise MAS-regulated institutions, multinational treasury operations, and corporate service providers on KYC obligations, beneficial owner disclosure, and correspondent banking requirements in Singapore and across Asia-Pacific. The firm's banking and finance practice covers regulated entities in over 20 jurisdictions, supported by a network of local counsel with direct regulatory experience. Our attorneys have advised on AML-related compliance matters across both civil law and common law systems. Additionally. The firm's Lisbon base provides direct access to EU regulatory frameworks alongside our common law expertise for enforcement and advisory work in English-speaking jurisdictions. Engaging a lawyer in Singapore with cross-border AML experience is essential when your entity's structure spans multiple jurisdictions – our team brings that combined perspective to every matter. As an international law firm in Singapore and beyond, Ferraz & Whitmore helps build compliance strategies that withstand regulatory scrutiny. To discuss your AML compliance position in Singapore, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.
Published: April 04, 2026
Author: Anna Chen – Senior Associate, Asia-Pacific, Middle East & CIS
Anna Chen is a Senior Associate at Ferraz & Whitmore focusing on cross-border transactions, market entry, and dispute resolution across Asia-Pacific, Middle Eastern, and CIS jurisdictions. She supports international clients in navigating regulatory and commercial challenges in high-growth and emerging markets.