AML Laws and Regulations for Approved Trustees for Collective Investment Schemes in Singapore
In a Nutshell
- An approved trustee is a public company approved by the Monetary Authority of Singapore (MAS) under section 289 of the Securities and Futures Act 2001 to act as trustee for an authorised collective investment scheme (a retail unit trust) in Singapore.
- Approved CIS trustees are MAS-regulated financial institutions. Their core AML/CFT rulebook is MAS Notice SFA 13-N01 (in force from 1 July 2025), read with its MAS Guidelines.
- Their duties cover a risk-based approach, customer due diligence (CDD), beneficial ownership identification, politically exposed person (PEP) and sanctions screening, ongoing monitoring, record-keeping, and suspicious transaction reporting (STR).
- Singapore rates collective investment schemes as low money laundering and terrorism financing risk. Even so, approved trustees carry the full weight of the AML laws and regulations, the CDSA, TSOFA, the UN and MAS sanctions regimes, FATF standards, and layered MAS guidance.
- This guide explains every applicable instrument in plain English, grounded in the primary sources, so an approved trustee can see exactly what applies to its sector.
AML Laws and Regulations for Approved Trustees for CIS in Singapore
Singapore is one of the world’s leading asset-management centres. Approved trustees play an important role in the collective investment schemes ecosystem. They hold and safeguard the assets of authorised unit trusts on behalf of investors. That gatekeeping role places them squarely inside Singapore’s anti-money laundering and counter terrorism financing (AML/CFT) framework.
The legal instruments themselves are broadly common across financial institutions. What matters to an approved trustee is how each one applies to its own sector. This article maps the full framework instrument by instrument. It covers the AML laws and regulations for approved trustees for collective investment schemes in Singapore, and states what each one means for the trustee’s day-to-day compliance.
Along the way, it shows how the Monetary Authority of Singapore (MAS) supervises approved trustees, how customer due diligence and suspicious transaction reporting operate in practice, and how Singapore’s national risk assessments shape each trustee’s defence against money laundering and terrorism financing.
The sector by the numbers
- Singapore’s total assets under management (AUM) reached about S$6.07 trillion (US$4.7 trillion) in 2024, up 12% year-on-year (MAS 2024 Singapore Asset Management Survey).
- Collective investment schemes accounted for roughly S$191 billion (US$148 billion) of that AUM.
- 1,298 registered and licensed fund management companies operate in Singapore.
- As at 31 December 2023 there were 1,590 collective investment schemes (312 authorised, 1,278 recognised) and 40 REITs, served by about 16 MAS-approved trustees.
- Enforcement is real: about S$6 billion in assets linked to criminal activity was seized between January 2019 and June 2024; the August 2023 case alone saw more than S$3 billion seized or restrained.
Core AML Laws and Regulations in Singapore
These are the statutes that create Singapore’s money-laundering and terrorism-financing offences and its sanctions duties. They are the foundation on which every approved trustee’s AML/CFT programme is built.
Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992
The CDSA is Singapore’s principal money-laundering statute and a core AML law for approved trustees. It criminalises handling criminal proceeds (sections 50, 51, 53 and 54) and imposes the suspicious transaction reporting duty in section 45: report to the STRO when you know or suspect that property is criminal proceeds. Section 57 forbids tipping-off. It underpins every STR and an approved CIS trustee file.
Terrorism (Suppression of Financing) Act 2002
The Terrorism (Suppression of Financing) Act 2002 is Singapore’s core counter terrorism financing law. Sections 3 to 6 criminalise dealing in terrorist property; section 8 requires an approved trustee to inform the Commissioner of Police of any terrorist property it holds, and section 10B forbids tipping-off. Penalties reach ten years and S$500,000. It drives the trustee’s sanctions screening and freezing.
United Nations Act 2001
The United Nations Act 2001 lets Singapore implement UN Security Council sanctions, including asset freezes. It is the statutory backbone of Singapore’s UN-mandated targeted financial sanctions, which every approved CIS trustee must screen for and enforce over scheme assets.
Financial Services and Markets (Sanctions and Freezing of Assets of Persons, Democratic People's Republic of Korea) Regulations 2023
Made under the Financial Services and Markets Act 2022, Regulation 3 outlines that these regulations apply to every financial institution, including approved trustees. These regulations implement UN sanctions on North Korea, and Regulation 13 requires immediate freezing of designated persons’ assets and Regulation 18 requires informing MAS. For a trustee, these are strict-liability sanctions-screening and freezing duties over unit-trust assets.
Financial Services and Markets (Sanctions and Freezing of Assets of Persons, Iran) Regulations 2023
These MAS regulations implement a UN Security Council Resolution on Iran and run parallel to the DPRK regime. Regulation 5 requires an approved trustee to freeze designated persons’ funds without delay and make nothing available to them, and Regulation 7 restricts dealings with Iran-linked persons. Live screening of unit-holders, settlors and counterparties is mandatory.
Overarching AML Laws and Regulations Applicable to Approved Trustees in Singapore
These instruments govern how an approved trustee actually detects and reports suspicion. They turn the statutory STR duty into a practical, day-to-day process.
The Suspicious Transaction Report (STR) Form Guide (Version 32)
The Suspicious Transaction Report (STR) Form Guide explains how to complete the report filed to the Suspicious Transaction Reporting Office (STRO). Filing an STR is how an approved CIS trustee meets its duty under the CDSA and under TSOFA when it suspects money laundering or terrorism financing. The grounds-of-suspicion narrative is the key field; version 32 supports virtual-asset reporting.
STRO Online Notices and Reporting Platform (SONAR)
SONAR is the STRO Online Notices and Reporting platform through which suspicious transaction reports are filed electronically. Access is set up through CorpPass and Singpass, with Submitter, Reviewer and Administrator roles. An approved trustee should set up SONAR access in advance so it can file promptly whenever it forms a suspicion, regardless of amount.
Terrorism Financing Red-Flag Indicators
The Terrorism Financing Indicators list sets out red flags grouped by category, such as CDD anomalies, unusual fund movement, structuring, and dealings with high-risk jurisdictions or designated persons. For an approved trustee, they support detection at onboarding and during monitoring. A single indicator is not proof, but a formed suspicion means filing an STR via SONAR without delay.
National Risk Assessments Relevant to Approved Trustees in Singapore
Singapore’s national risk assessments (NRAs) set the baseline that every approved trustee’s own enterprise-wide risk assessment must reflect.
Money Laundering National Risk Assessment Singapore 2024
The Money Laundering National Risk Assessment 2024, by MAS, MHA and MOF, names fraud, organised crime, corruption, tax crimes and trade-based laundering as the top threats and rates banking highest. Crucially, it records 16 approved trustees at the end of 2023, finds no misuse of an approved trustee for money laundering, and rates the sector as lower risk. It is the baseline for the trustee’s enterprise-wide risk assessment.
Money Laundering and Terrorism Financing Risk Assessment of Legal Persons in Singapore 2024
This assessment covers companies and other legal persons, which often appear as CIS managers, settlors or investors. It rates companies and unregistered foreign companies as high-risk for money laundering. For an approved trustee, the message is clear: treat corporate investors and ownership layers as the highest-risk vector, verify beneficial owners, and apply enhanced due diligence to opaque or foreign structures.
Terrorism Financing National Risk Assessment Singapore 2024
The Terrorism Financing National Risk Assessment 2024 rates Singapore’s overall TF risk as medium-low, with remittances and banks highest and digital payment tokens raised to medium-high. An approved trustee must screen customers and beneficial owners against terrorist designations, apply the TF indicators, and file suspicious transaction reports where concerns arise.
Singapore's 2024 Proliferation Financing National Risk Assessment and Counter Proliferation Financing Strategy
Singapore’s 2024 Proliferation Financing National Risk Assessment identifies misuse of legal persons, ship-to-ship transfers, dual-use goods and virtual assets as key threats, with banks and corporate service providers most exposed. As financial institutions, CIS trustees must comply with targeted financial sanctions and must screen and freeze designated-party exposure without delay.
Environmental Crimes Money Laundering National Risk Assessment 2024
This assessment covers laundering of environmental-crime proceeds, with Singapore assessed mainly as a transit country and trade-based laundering the dominant typology. For an approved trustee, the relevance is indirect: where scheme funds or counterparties touch forestry, mining, commodities or opaque trade structures, factor in environmental crime proceeds and check the source of funds.
Virtual Assets Risk Assessment
The Virtual Assets Risk Assessment reviews money laundering, terrorism financing and proliferation financing risks of digital payment tokens, flagging pseudonymity, fraud, ransomware and rapid cross-border transfer. Digital payment token service providers carry higher inherent risk. For an approved trustee, the lesson is exposure by association: if a scheme gains virtual asset exposure, extend AML/CFT controls, monitoring and source-of-funds scrutiny to it.
Sector ML/TF Risk Snapshot for Approved CIS Trustees
Risk area | Singapore rating | What it means for an approved trustee |
Collective investment schemes / REITs (as legal arrangements) | Low ML · | Low inherent risk, but full CDD, beneficial ownership and monitoring duties still apply. |
Express trusts held by trust companies | Medium-High ML | Contrast case; heightened scrutiny where trust structures sit in the ownership chain. |
Companies / foreign companies (investors, ownership layers) | High ML | Treat corporate investors and layers as the highest-risk vector; verify beneficial owners. |
Overall national terrorism-financing risk | Medium-Low | Screen against designations; watch links to remittance and NPO flows. |
Proliferation financing | Higher for banks, DPT, CSPs | Sanctions screening and freezing are mandatory for all financial institutions. |
Virtual assets | Higher inherent risk | Extend controls and monitoring if a scheme has any virtual-asset exposure. |
Environmental crime | Transit country exposure | Add source-of-funds checks where funds touch trade or resource sectors. |
Ratings drawn from Singapore’s 2024 National Risk Assessments.
MAS Guidance Applicable to Approved Trustees in Singapore
This is the heart of the framework. MAS guidance divides into two layers: common instruments that apply to financial institutions generally (and so to trustees), and instruments issued specifically for approved trustees of collective investment schemes.
Common Law for Financial Institutions in Singapore
These MAS instruments apply across financial institutions.
The Financial Services and Markets Act 2022
The Financial Services and Markets Act 2022 is MAS’s omnibus statute for financial institutions and the source of its AML/CFT powers over approved trustees. Under section 16, MAS can prescribe customer due diligence, record-keeping and other AML/CFT requirements. Section 15 lets MAS make sanctions and asset-freezing regulations to meet UN obligations. The Act also carries technology-risk and information-sharing powers. For an approved trustee, it is the legal foundation beneath the MAS Notices it must follow, and breaches are offences.
MAS Guidelines Applicable to Approved Trustees in Singapore
These MAS instruments apply across financial institutions and therefore bind approved trustees. They set out how MAS expects CDD, source-of-wealth checks, sanctions detection, monitoring and audit to be performed.
MAS Circular AMLD 02/2023: ML/TF Risks in the Wealth Management Sector
This MAS circular, dated 3 March 2023, warns all financial institutions to stay alert to money-laundering and terrorism-financing risks in wealth management. For an approved trustee handling fund and trust structures, it is directly relevant. MAS expects three things: stronger board and senior-management oversight of high-growth areas; added review and quality testing of customer due diligence, especially source of wealth and source of funds; and vigilance over higher-risk customers, piercing complex structures such as trusts and family offices to the true beneficial owners. Tax incentives are not proof of legitimacy.
MAS Circular AMLD 11/2023: Ensuring Effective Detection of Sanctions-Related Risks
Dated 31 August 2023, this circular sharpens how financial institutions detect sanctions risk. An approved trustee must keep abreast of all applicable sanctions, including foreign ones, and maintain strong board and senior-management oversight, a clear risk appetite, trained staff and escalation. MAS reiterates zero tolerance for breaches: freeze the assets and file a suspicious transaction report. It promotes better detection through data analytics and a risk-based lookback of past transactions with newly designated persons. For a trustee, screening must be current and able to catch indirect exposure through ownership chains, not just direct name matches.
MAS Circular AMLD 05/2026: Risk-Proportionate Source of Wealth Establishment
This recent circular, dated 25 May 2026, keeps source-of-wealth work proportionate so legitimate investors are not overburdened. For an approved trustee onboarding manager, settlors or unit-holders, it favours materiality and relevance over a one-size-fits-all approach. Its principles are simple: corroborate the material or higher-risk source of wealth rather than every item; ask only for relevant information; and match the depth of checks to the customer’s risk. Where red flags appear, escalate to senior management, which decides whether to proceed and applies ongoing oversight. It is read with the ACIP source-of-wealth best-practice paper.
MAS Circular AMLD 08/2024: Establishing the Sources of Wealth of Customers
Dated 26 July 2024, this circular gives detailed guidance on establishing and corroborating a customer’s source of wealth, prompted by Singapore’s large money-laundering cases. MAS expects independent corroboration against documentary evidence or reliable public sources, applying materiality, prudence and relevance, with senior-management oversight of higher-risk accounts. For an approved trustee, it sharpens expectations where a manager, settlor or investor shows significant or opaque wealth. Recording a stated source is not enough: the trustee must reasonably satisfy itself the wealth is legitimate, calibrate its checks to risk, and document the basis for its conclusions.
MAS Circular AMLD 01/2018: Use of MyInfo and CDD for Non-Face-to-Face Business Relations
Dated January 2018, this circular supports safe remote onboarding. MAS accepts MyInfo as a reliable, independent source to verify a customer’s name, identification number, date of birth, nationality and address, so extra identity documents and a photograph are not needed. Customers outside MyInfo, such as many non-residents, stay under standard due diligence. Where identity is taken through other non-face-to-face means, the approved trustee must add checks against impersonation, such as video conferencing, secure digital signatures or biometrics linked to the customer. New technology needs an independent assessment, kept while in use and for five years after.
MAS Circular AMLD 01/2022: Non-Face-to-Face Customer Due Diligence Measures
Dated 8 February 2022, this circular builds on the 2018 guidance and sets good practices for non-face-to-face customer due diligence. For an approved trustee onboarding investors or verifying connected parties and beneficial owners remotely, it covers individuals, through MyInfo, video conferencing, liveness checks and biometrics, and legal persons, through registry checks. Documents without authenticity markers should not be verified by video call alone. The trustee must assess any new technology itself before use, with board and senior-management approval, rather than relying on vendor assurances, and monitor it over time. It expressly addresses spoofing and deepfake risk.
MAS Circular AMLD 12/2024: Audit of AML/CFT Policies, Procedures and Controls
Dated 21 October 2024, these circular addresses the independent AML/CFT audit that financial institutions must maintain. An approved trustee needs policies that steer periodic audits and escalate findings to the board and senior management. MAS expects the audit function to be resourced with real AML/CFT expertise, supplemented by external help where needed. Audit scope should follow the trustee’s risk assessment, with frequency and depth matched to the risks and higher-risk areas prioritised. MAS also encourages data analytics in audit and a gap analysis against industry best practice. Independent testing, not just written policies, is the expectation.
MAS Information Paper: AML/CFT Supervisory Expectations from Recent Inspections (2024)
This MAS information paper, from October 2024, distils expectations from recent AML/CFT inspections. It sets no new rules, but an approved trustee should benchmark against it and run a gap analysis. It covers five areas: assessing customer risk, including multiple nationalities and investment-migration schemes; spotting and escalating material red flags; establishing source of wealth with rigour matched to risk; risk-mitigation steps, including after filing a report or exiting an account; and holistic monitoring that shares information across business units. Senior management should own the gap review and follow up promptly.
MAS Guidelines on Provision of Digital Advisory Services (2018)
Issued in October 2018, these guidelines set MAS’s expectations for digital, or robo, advisory services that give algorithm-based advice with limited human contact. They matter where an approved trustee or its group supports digital advice tied to collective investment schemes. Alongside licensing, algorithm governance, suitability and disclosure, they confirm that digital advisers, like other financial institutions, must maintain AML/CFT policies, procedures and controls under the applicable MAS Notices. Because onboarding is online, they must manage non-face-to-face impersonation risk, drawing on the MyInfo and remote CDD guidance. They connect product conduct with the same onboarding discipline.
MAS Information Paper: Strengthening AML/CFT Controls Against Misuse of Legal Persons, Arrangements and Complex Structures (2023)
This MAS information paper, from August 2023, addresses misuse of legal persons, legal arrangements and complex structures, a key risk for an approved trustee dealing with trusts and layered ownership. It sets out typologies, inspection observations and case studies, including pass-through and round-tripping flows with no clear purpose, and layers built only to hide beneficial ownership. It expects due diligence that understands the purpose of a structure and identifies the true owners and controllers, plus ongoing monitoring supported by data analytics to spot shell and front-company red flags. Benchmark against it, with senior-management oversight.
MAS Information Paper: Effective Practices to Detect and Mitigate the Risk from Misuse of Legal Persons (2019)
This MAS information paper, from June 2019, shares effective practices against misuse of legal persons, drawn from thematic bank inspections. MAS expects other financial institutions to apply the lessons in a risk-based way. For an approved trustee, it is highly relevant, because scheme structures, corporate investors and manager entities can hide who really owns or controls the money. Through case examples, it shows how shell companies, layered ownership and nominees are used, and what good practice looks like: probing the economic rationale, verifying beneficial ownership over form, and scrutinising transactions that do not fit the customer’s profile.
MAS Guidelines on Risk Management Practices: Internal Controls (2024)
This is a MAS prudential guidelines document on internal controls, part of the Guidelines on Risk Management Practices, rather than a dedicated AML/CFT instrument. It still frames the control environment an approved trustee should maintain board and senior-management ownership, documented policies, segregation of duties, competent resources, independent audit and compliance, mandatory leave, and staff training. Its business-process controls cover customer dealings, customer due diligence, record-keeping and management information. The customer due diligence section requires satisfactory evidence of identity and legal existence before onboarding, no anonymous accounts, and enhanced checks for higher-risk customers, and points to the MAS AML/CFT Notices.
MAS Guidance: Guidance to Capital Markets Intermediaries on Enhancing AML/CFT Frameworks and Controls (2019)
Dated January 2019, this MAS guidance reports findings from AML/CFT inspections of capital markets intermediaries, and its key takeaways are to be calibrated depending on the type of financial institution. It uses three pillars. Governance expects the board and senior management to set the tone and oversee ML/TF risk. Risk Awareness expects a firm-wide grasp of the risks faced and the ability to escalate and mitigate them. Execution expects effective controls to detect, prevent and deter money laundering and terrorism financing. It offers findings and expectations under each pillar for a trustee to benchmark against.
MAS / ACIP Best Practices in Relation to Risks in Wealth Management (2025)
Produced by the AML/CFT Industry Partnership in May 2025, this paper compiles best practices for managing money-laundering and terrorism-financing risk in wealth management, through case studies. It is highly relevant to an approved trustee serving high-net-worth clients and complex structures. It covers risks from complex structures, macroeconomic and geopolitical shifts, non-face-to-face onboarding, clients’ nationality and residence, use of external asset managers, and ongoing monitoring. MAS’s later Circular AMLD 05/2026 asks firms to apply it in a targeted, risk-proportionate way. A trustee can use it to calibrate controls and to show alignment during inspection.
MAS Guidance: Sound Practices to Counter Proliferation Financing (2018)
Dated August 2018, this MAS guidance addresses proliferation-financing risk, driven by the DPRK and Iran and the UN’s list-based and activity-based sanctions. For an approved trustee, it clarifies how to meet existing sanctions duties as a gatekeeper. Drawing on thematic visits, it creates no new rules but offers a structured way to uplift controls: identifying higher-risk customers, monitoring for sanctions evasion typologies, and setting governance, risk awareness and accountability from the top. An annex lists proliferation-financing indicators. It confirms that MAS’s sanctions and freezing regulations apply to all MAS-regulated institutions, whatever the assessed risk.
MAS Guidance for Effective AML/CFT Transaction Monitoring Controls (2018)
Dated September 2018, this MAS guidance treats transaction monitoring as a key control, since risks hidden at onboarding often surface later. For an approved trustee, good monitoring detects suspicious activity in fund and trust flows against each customer’s profile, including proliferation financing risk. MAS describes an effective system as three things working together: a well-calibrated, risk-based framework, reviewed and updated on trigger events; competent, well-trained staff who exercise judgment; and real integration with the wider AML/CFT programme. It covers alert calibration and resolution, risk awareness, and governance, including where first-level alert reviews are materially outsourced.
MAS Guidance: Strengthening Financial Institutions' CFT Controls (2023)
Dated May 2023, this MAS paper sets expectations on counter-terrorism-financing controls, drawing on an industry survey and thematic reviews. An approved trustee should benchmark against it and remediate gaps promptly. It stresses that terrorism-financing risk, though quieter than money laundering, must be actively assessed, not assumed away. That means current name-screening against terrorism-designation lists, understanding TF typologies in fund and cross-border flows, and monitoring able to surface low-value or unusual activity. The trustee must not deal with UN-designated or First Schedule persons, must freeze and report, and should screen customers before any transaction.
Approved Trustees Sector-Specific MAS Notice
Specific Guidelines and Notices for Approved Trustees in Singapore
These instruments are issued specifically for approved trustees of collective investment schemes. They are the trustee’s core, direct obligations.
MAS Notice SFA 13-N01: Prevention of Money Laundering and Countering the Financing of Terrorism: Approved Trustees
MAS Notice SFA 13-N01 is the sector’s core AML/CFT rulebook. It is issued under section 16 of the Financial Services and Markets Act 2022, applies to every trustee approved under section 289 of the Securities and Futures Act, and took effect on 1 July 2025. Its defining feature for this sector is who the customer is: the manager of the collective investment scheme. In practice, the trustee’s regulated activity is entering into the trust deed with that manager and monitoring the manager’s transactions, so its due diligence runs to the manager, the people appointed to act for it, connected parties such as directors, and the beneficial owners behind it.
The Notice is built on a risk-based approach. The trustee must identify, assess and understand the money-laundering, terrorism-financing and proliferation-financing risks it faces across its manager customers, the jurisdictions involved, and its own products and channels. It must document that assessment, keep it current, and mitigate the risks through policies approved by senior management. Higher risk calls for more scrutiny; genuinely lower risk allows a lighter touch.
Customer due diligence is the heart of the Notice. Anonymous or fictitious-name dealings are prohibited. Before it begins business relations, the trustee identifies the manager, collects its key particulars and legal form, identifies connected parties, and verifies the manager’s identity and existence using reliable, independent sources. Where individuals are appointed to act for the manager, the trustee verifies both who they are and their authority to act.
Beneficial ownership gets particular attention. The trustee must look through the manager to the natural persons who ultimately own or control it, working through a cascade of ownership, then control, then senior management. A holding above 25 per cent is the working illustration of ownership, but a person who exercises control through other significant influence is a beneficial owner even below that level. The trustee must also understand the manager’s business and the purpose of the relationship. At least one verification step must be done face-to-face before relations begin, and remote onboarding must be just as robust.
Due diligence flexes with risk. Simplified checks are allowed only where risk is genuinely low, and never where a jurisdiction faces FATF countermeasures or has weak controls, or where laundering or terrorism financing is suspected. Enhanced due diligence is mandatory for politically exposed persons: the trustee needs senior-management approval to deal with them, must establish their source of wealth and source of funds, and must monitor them more closely. The same enhanced approach applies to other higher-risk cases, such as opaque structures with no clear economic purpose.
The trustee may rely on an eligible third party to perform customer due diligence, but never for ongoing monitoring, and it stays responsible for meeting its own obligations. That reliance is different from outsourcing, where a provider works under the trustee’s own procedures and control. Reflecting the sector, the Notice has no correspondent-banking or wire-transfer rules, because the trustee’s only customer is the manager and it does not provide those services.
Ongoing monitoring runs throughout the relationship. The trustee watches the manager’s transactions against what it knows of the manager and the fund’s mandate and screens the manager and connected parties against the MAS and United Nations lists before relations begin, periodically, and whenever a list or a party change. A positive sanctions match triggers three duties: freeze the assets of the designated person without delay, report the freeze to MAS, and file a suspicious transaction report.
Records of due diligence, transactions and analyses must be kept for at least five years. The trustee must file suspicious transaction reports with the STRO under the CDSA and TSOFA whenever suspicion arises, regardless of amount, and must never tip off the subject. Finally, the trustee must put the framework on a firm footing: written policies, a compliance officer at management level, an independent audit function, employee screening, and regular training.
Legal grounding: application and the customer definition sit in paragraphs 1 and 2 of the Notice; the risk-based approach in paragraph 4; customer due diligence, verification and beneficial ownership in paragraph 6; simplified and enhanced due diligence and PEPs in paragraphs 7 and 8; reliance on third parties in paragraph 9; record-keeping in paragraph 10; suspicious transaction reporting in paragraph 12; and compliance, audit and training in paragraph 13.
Guidelines to MAS Notice SFA 13-N01
The Guidelines to Notice SFA 13-N01 explain how to put the Notice into practice and are read alongside it. They carry real weight: how well a trustee observes them feeds directly into MAS’s view of the trustee’s governance, oversight and controls. Ultimate accountability for AML/CFT sits with the board and senior management, working through three lines of defence, namely the business, the compliance function, and internal audit.
The Guidelines expect a genuine enterprise-wide risk assessment. The trustee weighs its customer profile and how many higher-risk managers it serves, the jurisdictions its managers come from and operate in, and the nature and complexity of its products and channels. Senior management must approve the assessment, it must be documented and available to MAS, and it must be refreshed at least every two years or whenever something material changes. Controls and resources should then match the risks identified.
On customer due diligence, the Guidelines separate identification from verification and stress using reliable, independent evidence that is hard to forge or obtain illicitly, such as government identity documents and official registry reports. The depth of verification should match the manager’s risk. Information must be current, and staff should be trained to spot tampered documents and to escalate discrepancies quickly.
Beneficial ownership is explained in depth. The steps of ownership, then control, then senior managing official are a cascade, not a menu: each is used only where the one before it has not identified a real person. The more-than-25-per-cent test is an illustration, taking account of shares held across layers, and a person who controls the manager through significant influence still counts even below that threshold. The Guidelines call for extra care with bearer shares, nominee shareholders and layered or complex structures, which are treated as higher-risk indicators.
For politically exposed persons, senior-management approval is required, with input from the compliance function. The Guidelines explain the difference between source of wealth, meaning how the person’s overall wealth was built, and source of funds, meaning where the specific money in the relationship came from, and expect the trustee to look past the transferring bank to the activity that generated the funds. Both should be corroborated with reliable, independent sources, with effort focused on the material or higher-risk elements.
The Guidelines draw a clear line between reliance and outsourcing and remind the trustee that it remains responsible either way. Ongoing monitoring should cover every relationship, with more attention where risk is higher, and due diligence information should be refreshed on trigger events such as a significant transaction, a material change in how the relationship runs, or a change in the trustee’s own policies.
A dedicated proliferation-financing chapter tells the trustee to use its due diligence and screening to catch proliferation-financing risk, to screen against the latest United Nations sanctions lists, and to watch those lists for updates. On a match, the trustee must freeze the relevant funds or assets immediately, report the freeze to MAS, and file a suspicious transaction report without delay. The chapter also lists warning signs, such as evasive customers and dealings involving designated persons or shell companies.
On reporting, the Guidelines set a filing standard of no later than five business days after suspicion forms, tightened to one business day where a sanctioned party is involved, and confirm that a report to the STRO also satisfies the TSOFA duty. A decision not to file must be reasoned and documented. Worked examples round off the guidance: one appendix lists the due-diligence information to collect by customer type, and another gives trustee-specific red flags, such as unusually large subscriptions or redemptions and manager transactions that make no economic sense.
Legal grounding: the status and governance expectations are in chapter 1 of the Guidelines; the enterprise-wide risk assessment in chapter 4; customer due diligence and beneficial ownership in chapter 6; PEPs and source of wealth and funds in chapter 8; reliance in chapter 9; the proliferation-financing measures in Part I; suspicious transaction reporting in chapter 12; and worked examples in the appendices.
MAS Notice CMG-N01: Reporting of Suspicious Activities and Incidents of Fraud
MAS Notice CMG-N01, on reporting suspicious activities and incidents of fraud, is issued under the Securities and Futures Act and applies to approved CIS trustees. First issued in 2013 and last revised in August 2024, it requires the trustee to report to MAS, on Form F1 and within five working days, any suspicious activity or fraud incident that is material to its safety, soundness or reputation. This is separate from and additional to the suspicious transaction report filed with the STRO: CMG-N01 captures institutional fraud and reputational incidents. A decision not to report must be documented.
MAS Notice PSM N01: Prevention of Money Laundering and Countering the Financing of Terrorism Financial Institutions Dealing in Precious Stones and Precious Metals PSM N01
MAS Notice PSM N01 applies to all financial institutions, including approved trustees for collective investment schemes, in relation to the carrying on of a business of regulated dealing or as an intermediary for regulated dealing which includes manufacturing any precious stone, precious metal or precious product; importing or possessing for sale any precious stone, precious metal or precious product; selling or offering for sale any precious stone, precious metal or precious product; selling or redeeming any asset backed tokens; purchasing any precious stone, precious metal or precious product for resale.
Allied Laws Applicable to Approved Trustees in Singapore
These supporting statutes reinforce the AML/CFT regime. Some define the trustee’s own legal duties; others create predicate offences or the investigation powers that make the regime enforceable.
Trustees Act 1967
The Trustees Act 1967 sets every trustee’s baseline duty. Section 3A imposes a statutory duty of care, higher for professional trustees, and it governs investment powers and the appointment of and liability for agents, nominees and custodians holding scheme assets.
Securities and Futures Act 2001
The Securities and Futures Act 2001 provides the statutory framework for collective investment schemes and the regulation of their approved trustees. Section 289 empowers MAS to approve persons to act as approved trustees, subject to the applicable regulatory requirements, and provides the framework for approval and regulatory action where an approved trustee fails to meet its obligations.
Monetary Authority of Singapore Act 1970
The Monetary Authority of Singapore Act 1970 establishes MAS and its integrated supervision mandate. It underpins MAS’s power to approve CIS trustees, issue binding AML/CFT notices, and inspect and enforce across an approved trustee’s business.
Prevention of Corruption Act 1960
The Prevention of Corruption Act 1960 criminalises bribery, a money laundering predicate, and defines agent to include a trustee. Corruption proceeds moving through a scheme create predicate exposure and reinforce an approved trustee’s source-of-wealth scrutiny, especially around PEPs.
Criminal Procedure Code 2010
The Criminal Procedure Code 2010 supplies the investigation machinery for money laundering cases: production orders, search and seizure, and prohibition of dealing with suspected criminal property. An approved trustee served with such an order must comply, preserve records and avoid tipping off.
Strategic Goods (Control) Act 2002
The Strategic Goods (Control) Act 2002 controls export and brokering of strategic and dual-use goods and is a proliferation financing predicate. An approved trustee holding or funding assets tied to controlled goods should screen counterparties; section 6(7) offers only a narrow financing carve-out.
Chemical Weapons (Prohibition) Act 2000
The Chemical Weapons (Prohibition) Act 2000 implements the Chemical Weapons Convention and is a proliferation financing predicate, reaching anyone who knowingly assists prohibited activity. An approved trustee must not let scheme funds reach persons linked to chemical weapon activity, reinforcing sanctions screening.
Biological Agents and Toxins Act 2005
The Biological Agents and Toxins Act 2005 regulates biological agents and is a proliferation financing predicate, prohibiting dealings for a non-peaceful purpose. For an approved trustee, scheme funds must not finance biological weapon activity, underscoring enhanced due diligence on higher-risk life science counterparties.
Miscellaneous Laws, Strategies and Guidance Applicable to Approved Trustees in Singapore
National Anti-Money Laundering Strategy 2024
Singapore’s National Anti-Money Laundering Strategy 2024 sets a Prevention, Detection and Enforcement framework and commits to strengthening trust beneficial ownership rules, including Trustees Act amendments. An approved trustee should read it as the policy direction shaping its supervision and beneficial ownership duties.
National Asset Recovery Strategy 2024
The National Asset Recovery Strategy 2024 explains how Singapore seizes and confiscates illicit proceeds across four pillars. For an approved trustee, the relevance is the regime that can reach trust-held assets suspected of being criminal proceeds, supported by prompt suspicious transaction reporting.
National Strategy for Countering the Financing of Terrorism 2022
The National Strategy for Countering the Financing of Terrorism 2022 aligns Singapore’s targeted financial sanctions with UN resolutions. For an approved trustee, it frames the CFT duties of screening customers and beneficial owners against terrorist designations, freezing of assets, and filing of suspicious transaction reports.
Singapore Law Enforcement Strategy to Combat Money Laundering 2024
The Singapore Law Enforcement Strategy to Combat Money Laundering explains how the Police, CNB and CPIB investigate laundering. It signals that AML/CFT regulators will increasingly access the STRs their regulated entities file, sharpening supervision of approved trustees.
Inter-Ministerial Committee on Anti-Money Laundering Report 2024
The Inter-Ministerial Committee Report 2024 recommends stronger gatekeeper AML standards: clearer CDD, source of wealth and beneficial ownership expectations and deterrence of corporate structure misuse, all mapping onto how an approved trustee onboards and monitors.
Legal Persons: Misuse Typologies and Best Practices
The ACIP Legal Persons Misuse Typologies paper sets out seven misuse typologies. Its private investment fund and hidden ownership typologies speak directly to an approved trustee, whose scheme and investor structures can disguise control, and its red flags map onto CDD and monitoring.
International Standards Shaping AML/CFT for Approved Trustees in Singapore
Singapore’s AML/CFT regime is built to meet the FATF international standards. These instruments explain why an approved trustee’s obligations look the way they do, and where global expectations are heading.
The FATF Recommendations
The FATF Recommendations are the global AML, CFT and CPF standard Singapore’s regime is built to meet. For an approved trustee, the most relevant recommendations are Recommendations 10, 12, 24 and 25; they set CDD, cover PEPs, and govern beneficial ownership of companies and trusts, respectively.
FATF Methodology for Assessing Technical Compliance and Effectiveness of AML/CFT/CPF Systems
The FATF assessment methodology provides a standardised framework for evaluating Singapore’s technical compliance with the Recommendations. MAS’s supervisory effectiveness is therefore influenced by how well approved trustees and other regulated institutions implement preventive measures in practice.
Mutual Evaluation Report of Singapore 2026
The 2026 FATF and APG Mutual Evaluation of Singapore rates beneficial ownership transparency as only moderate and Recommendations 24 and 25 as partially compliant, signalling sustained MAS pressure on trust beneficial ownership records and proliferation financing controls for approved trustees.
FATF Guidance on Beneficial Ownership of Legal Persons 2023
This FATF guidance interprets the strengthened Recommendation 24 on beneficial ownership of companies, covering registries, verification and controls on nominees and bearer shares. An approved trustee applies it when a corporate investor or settlor sits in a scheme’s ownership chain.
FATF Best Practices on Beneficial Ownership for Legal Persons 2019
These FATF best practices paper explains how to keep beneficial ownership information for legal persons accurate and up to date across the registry, company and existing information approaches. It helps an approved trustee look through a corporate unit holder to the natural persons in control.
FATF Guidance on Beneficial Ownership and Transparency of Legal Arrangements 2024
This is the most relevant international standard for a trustee. Implementing Recommendation 25, it requires beneficial ownership information for every party to a trust: settlor, trustee, protector and beneficiaries. As trustee of a unit trust, an approved trustee sits squarely within its scope.
FATF-Egmont Group Report on Concealment of Beneficial Ownership 2018
This FATF and Egmont Group report shows how shell companies, nominees and complex structures hide true owners, often via professional intermediaries. An approved trustee is both a potential target and a gatekeeper expected to see through such layers in scheme relationships.
FATF Guidance on Politically Exposed Persons
This FATF guidance covers politically exposed persons (PEPs) under Recommendations 12 and 22. Foreign PEPs are always high risk, needing senior-management approval and source-of-wealth checks. An approved trustee applies it when a PEP, or a beneficial owner behind an investor, holds units.
FATF Guidance on Digital Identity 2020
This FATF guidance explains when digital identity systems can perform CDD, and that well-assured non-face-to-face onboarding may be standard risk. For an approved trustee onboarding investors online, it supports digital verification once the identity system’s assurance level is assessed.
FATF Guidance on Proliferation Financing Risk Assessment and Mitigation 2021
Following the 2020 revision of Recommendation 1, this FATF guidance requires firms to assess and mitigate proliferation financing risk, meaning evasion of targeted financial sanctions. An approved trustee should document a proportionate assessment and screen investors and counterparties against UN lists.
FATF Guidance on Countering Proliferation Financing 2018
This FATF guidance explains proliferation financing targeted sanctions under Recommendation 7 and the UN approach to the DPRK and Iran. It underpins an approved trustee’s duty to screen, freeze without delay, and avoid serving designated persons or their fronts.
FATF Report on Money Laundering from Environmental Crime 2021
This FATF report shows how environmental crime proceeds are laundered through trade-based fraud and shell companies. Environmental crime is a predicate offence, so where scheme funds touch forestry, mining or commodities, an approved trustee should weigh it in source-of-funds checks.
FATF-Egmont Group Handout on Trade-Based Money Laundering
This FATF and Egmont Group handout explains trade-based money laundering through over- and under-invoicing and phantom shipments. Where scheme assets or investor funds link to import-export or commodity businesses, an approved trustee should watch for price and quantity mismatches.
FATF Report on Artificial Intelligence and Deepfakes: Impacts on ML/TF/PF
This FATF report assesses how AI, especially deepfakes, can defeat CDD and digital-identity checks. For an approved trustee onboarding investors remotely, it is a warning to build liveness detection and controls that resist AI-generated identity spoofing.
Summary: Key Instruments and What They Require of Approved Trustees
The framework is broad, but a handful of instruments carry most of the day-to-day obligations. This table maps the most operationally important AML laws and regulations for approved trustees for collective investment schemes in Singapore to the duties they create.
Instrument | Type | What it requires of an approved trustee |
CDSA 1992 | ML offences, confiscation and STR obligations | Do not deal with or assist in transactions involving criminal proceeds, file STRs to STRO under section 45, comply with the prohibition on tipping-off. |
TSOFA 2002 | TF offences and disclosure obligations | Do not deal with terrorist property or facilitate terrorist financing, Screen for terrorist links, inform Police of terrorist property, disclose TF information. |
UN Act 2001 + FSM (DPRK & Iran) Regs 2023 | Targeted financial sanctions | Screen relevant parties against applicable sanctions lists, freeze assets or funds of designated persons’ assets without delay. |
Securities and Futures Act 2001 (s.289) | Licensing and regulatory framework | Comply with applicable licensing, regulatory and conduct requirements, including requirements concerning the safeguarding and administration of scheme assets. |
Trustees Act 1967 | General Trustee duties | Exercise the duties imposed on trustees under the trust law, including appropriate care in administering trust property and proper oversight of persons or agents appointed to assist in administering the trust. |
Financial Services and Markets Act 2022 | MAS supervisory and rule-making power | Comply with applicable MAS AML/CFT Notices, regulations and directions issued under the Act. Breaches may result in regulatory enforcement and penalties. |
MAS Notice and guidelines SFA 13-N01 (2025) | Core AML/CFT notice and guidelines | Operationalise the preventive measures, including risk assessment, CDD, and identification and verification of customers and beneficial owners. |
MAS Notice CMG-N01 | Regulatory and Incident reporting | Report material suspicious activity or fraud to MAS through Form F1 within 5 working days. |
MAS Circulars AMLD 05/2026 & 08/2024 | Source of wealth guidance | Apply appropriate measures to establish and where necessary, independently corroborate source of wealth, proportionate to the customer’s ML/TF risk, with appropriate escalation and senior management involvement. |
MAS Circulars AMLD 01/2018 & 01/2022 | Non-face-to-face CDD | Apply appropriate controls when conducting remote or non-face-to-face onboarding. |
MAS Circular AMLD 11/2023 | Sanctions screening | Maintain effective and up-to-date sanctions screening, controls, conduct appropriate look-backs where required, and take the prescribed action when designated persons or frozen assets are identified. |
MAS Circular AMLD 12/2024 | Independent AML/CFT audit | Maintain an independent and appropriately risk-based audit to assess the effectiveness of the AML/CFT framework and controls. |
FATF Recommendations and Methodology | International standards | Provide the international AML/CFT/CPF standards that underpin Singapore’s regulatory framework and risk-based approach. |
FATF Legal-Arrangements BO Guidance (2024) | Trust beneficial ownership standards | Ensure that relevant beneficial ownership and control information concerning legal arrangements is properly identified and maintained. |
National Risk Assessments 2024 | National ML/TF/PF risk assessment | Use the findings to inform the trustee’s own enterprise-wide risk assessment, risk-based controls and allocation of compliance resources. |
Conclusion
For an approved trustee of a collective investment scheme, AML/CFT compliance is not an add-on. It is built into the role. MAS approves and supervises the trustee and expects it to act as an effective gatekeeper over the scheme and the assets it administers.
Singapore’s national risk assessments identify collective investment schemes as a low-risk sector for money laundering. But low risk does not mean low obligation. An approved trustee must still maintain a full, documented, risk-based AML/CFT programme covering customer due diligence, beneficial-ownership identification, PEP and sanctions screening, ongoing monitoring, record-keeping and suspicious transaction reporting. These obligations sit within the framework of MAS Notice SFA 13-N01 and its Guidelines, supported by the CDSA, TSOFA, applicable sanctions legislation and regulations, FATF standards, and MAS’s broader AML/CFT guidance.
The broader regulatory direction is also clear: beneficial ownership transparency, source-of-wealth verification and proliferation-financing controls are receiving increasing attention. Approved trustees that keep their enterprise-wide risk assessment current, establish who ultimately owns and controls the assets and relationships they oversee, and can demonstrate that their controls work in practice, not merely that policies exist on paper, will be better positioned to meet MAS’s supervisory expectations.
Frequently Asked Questions
An approved trustee is a public company that MAS has approved under section 289 of the Securities and Futures Act 2001 to act as trustee for an authorised collective investment scheme, typically a retail unit trust. The trustee holds and safeguards the scheme’s assets on behalf of investors, independently of the fund manager. To be approved, the company must meet fitness-and-propriety and financial requirements, and its CEO and directors must also be approved by MAS.
The core sector-specific instrument is MAS Notice SFA 13-N01 on the Prevention of Money Laundering and Countering the Financing of Terrorism for Approved Trustees, in force from 1 July 2025, read with its MAS Guidelines.
Yes. An approved trustee is a MAS-regulated financial institution and is subject to the full AML/CFT regime. That is why MAS Notice SFA 13-N01 is issued under section 16 of the Financial Services and Markets Act 2022 and why the MAS sanctions and asset-freezing regulations apply directly to approved trustees.
The main duties include adopting a documented, risk-based approach; performing customer due diligence on the connected parties and beneficial owners; identifying beneficial owners (generally natural persons owning or controlling more than 25 per cent); screening for PEPs and against sanctions lists; conducting ongoing monitoring; keeping records for at least five years; and filing suspicious transaction reports. The trustee must also maintain a compliance function, an independent audit and staff training.
The beneficial owners of a trust include the settlor, the trustee, the protector (if any), the beneficiaries or classes of beneficiaries, and any other natural person exercising ultimate effective control. An approved trustee must hold complete, accurate and up-to-date information on all these parties and be able to make it available to competent authorities.
Yes. Under section 45 of the CDSA and the disclosure duties in TSOFA, an approved trustee must file a suspicious transaction report with the STRO (through the SONAR platform) whenever it has reasonable grounds to suspect money laundering or terrorism financing, regardless of the amount involved. Failing to report and tipping off are offences. Separately, material suspicious activity or fraud must be reported to MAS under Notice CMG-N01.
Singapore’s 2024 Risk Assessment of Legal Arrangements rates collective investment schemes, including REITs, as low for both money laundering and terrorism financing risk. MAS attributes this to CIS being managed by regulated fund managers, overseen by an approved trustee, and subject to strict transparency under the Securities and Futures Act. Low inherent risk, however, does not reduce the trustee’s compliance obligations; it simply calibrates how the risk-based approach is applied.
About the Author
Pathik Shah
FCA, CAMS, CISA, CS, DISA (ICAI), FAFP (ICAI)
Pathik is a Chartered Accountant with more than 26 years of experience in governance, risk, and compliance. He helps companies with end-to-end AML compliance services, from conducting Enterprise- Wide Risk Assessments to implementing the robust AML Compliance framework. He has played a pivotal role as a functional expert in developing and implementing RegTech solutions for streamlined compliance.
