AML Laws and Regulations for Non-Bank Credit Card Issuers in Singapore

Table of Contents

In a Nutshell

A non-bank credit card (NBCC) issuer is a firm licensed under part 8 of the Banking Act 1970 to carry on the business of issuing credit or charge cards in Singapore. It issues cards that allow cardholders to pay merchants on credit. Because these cards have restrictions on cash payments, cash access and credit balances, their structural exposure to money laundering is limited, while fraud and the use of false or stolen identities remain more relevant concerns.

The core AML, CFT and CPF rulebook is MAS Notice 626A and its Guidelines. They establish requirements covering risk assessment, customer due diligence, enhanced measures for politically exposed persons, wire and value transfers, record keeping and suspicious transaction reporting. These requirements are tailored to the risks of credit and charge card businesses.

Singapore’s 2024 National risk assessment places non-bank credit card issuers as having a low money laundering risk band, noting that restrictions on cash payments, cash access and credit balances limit their usefulness as a vehicle for money laundering. Fraud, identity misuse and illicit funds used for repayment remain relevant risks.

Around this core sit the relevant criminal and sanctions statutes, the national risk assessments, the Banking Act licensing framework, and the FATF standards. Each instrument below in turn, in plain terms, with the specific source on which it is based.

AML Laws and Regulations for Non-Bank Credit Card Issuers in Singapore

A credit card is a relatively difficult product to use for money laundering because a cardholder cannot simply deposit cash and withdraw it again, yet a non-bank issuer still carries specific anti-money laundering duties. This guide sets out the laws and regulations that apply to non-bank credit issuers in Singapore, from the criminal statutes that make money laundering an offence to the detailed requirements imposed by the Monetary Authority of Singapore (MAS) on credit card issuers.

The framework is best read in layers. The criminal and sanctions laws form the foundation. Above them sits the instrument a non-bank card issuer works with most directly, MAS Notice 626A, together with its guidelines. Alongside these are Singapore’s national risk assessments, the Banking Act, which provides the licensing framework for the sector, and the FATF standards that underpin the wider regime. Each instrument below is explained through the lens of a non-bank card issuer, rather than in the abstract.

Because credit cards have limited cash in and cash out functionality, an issuer’s exposure is less about the classic layering of illicit funds and more about risks such as accounts being opened using stolen or false identities, or legitimate cards being misused. That shapes much of what follows, from how an issuer screens an applicant to how it monitors card activity.

Singapore's non-bank credit card issuers at a glance

There were four non-bank credit card issuers operating in Singapore as at the end of 2023, a small sector alongside the banks that issue most of the country’s credit cards (Money Laundering National Risk Assessment 2024, chapter 7.13).

Cards are used mainly by Singapore residents and certain corporate customers, such as those in the tourism sector, to pay for goods and services, and the products carry structural limits on cash and credit balances (ML NRA 2024, chapter 7.13).

Risk rating: the sector is assessed in the lower money laundering risk band, with structural controls limiting laundering and fraud the main threat the issuers manage (ML NRA 2024, chapter 7.13).

Core AML Laws and Regulations for Non-Bank Credit Card Issuers in Singapore

These statutes and sanctions regulations make money laundering, terrorism financing and proliferation financing offences and require NBCCs to detect and report them. They apply of their own force, whether or not a MAS notice repeats them, and the sector rulebook is layered on top.

The Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992

The CDSA is the core statute for Singapore’s money laundering regime and provides for the confiscation of benefits derived from drug dealing and criminal conduct. For NBCCs, section 45 creates a direct duty to disclose to the suspicious transaction reporting office when, in the course of business, the issuer knows or has reasonable grounds to suspect that property represents, has been used in connection with, or is intended to be used in connection with drug dealing or criminal activity. Section 57 makes tipping off an offence, preventing a person from improperly disclosing information that could prejudice a related investigation or disclosure.

The Terrorism (Suppression of Financing) Act 2002

The TSOFA makes it a crime to raise, collect or handle property for terrorism and to deal in terrorist property. NBCCs must not issue a card to, or process payments for, a person they know or have reasonable grounds to believe is a terrorist and must alert the authorities. In practice, the duty is discharged by screening the applicant and any connected party against the sanctions lists.

The United Nations Act 2001

This Act empowers the Minister to make regulations that give United Nations Security Council sanctions force in Singapore, and it stands behind the country’s measures. NBCCs apply the measures through the MAS sanctions regulations rather than this Act, because the Act gives way where a financial institution is already bound by MAS directions, so the issuers work under the MAS regime.

The Financial Services and Markets (Sanctions and Freezing of Assets of Persons, Democratic People's Republic of Korea) Regulations 2023

Issued by MAS under the Financial Services and Markets Act 2022, these regulations bring United Nations sanctions on North Korea into force and bind every financial institution, so NBCCs are covered. They must freeze a designated person’s assets without delay, must not issue a card to or process payments for them, and must report to MAS, with liability that does not turn on having known a party was listed.

The Financial Services and Markets (Sanctions and Freezing of Assets of Persons, Iran) Regulations 2023

The Iran regulations, also made by MAS under the FSM Act 2022, give Security Council Resolution 2231 domestic effect. NBCCs must freeze designated persons’ assets and must not provide services that could support proliferation financing, subject to narrow exemptions resting on a MAS determination. The live duty is screening the cardholder and connected parties against the sanctions lists.

Overarching AML Laws and Regulations Applicable to Non-Bank Credit Card Issuers in Singapore

These instruments run across the whole regime and give card issuers the practical means to meet their reporting duties and to recognise terrorism financing when it shows up on a card.

Getting Started with SONAR, for STR Filers (2025)

SONAR, the STRO Online Notices and Reporting platform, is the electronic platform through which card issuers submit their suspicious transaction reports to the suspicious transactions reporting office. The guide covers access, registration, administrator and user roles and the submission of STRs. For NBCCs, it is the operational channel for fulfilling their STR filing obligation under section 45 of the CDSA. Compliance teams use SONAR to submit reports electronically and maintain an appropriate record of their filings.

Form Guide for the STR Form (Version 12 August 2025)

A field-by-field guide to completing the electronic suspicious transaction report form. It explains the information required across the form, from the reporting institution’s details and reported entity profile to the description of the suspicious transaction activity. The form also requires the reporting institution’s reference number. For NBCCs, the guide helps its compliance team prepare a complete and properly supported STR when suspicious activity is identified in an application, account or pattern of card transactions.

Terrorism Financing Indicators

A red flag reference from STRO that groups terrorism financing indicators around due diligence anomalies, unusual movement of funds and transactions that lack an apparent economic rationale. For card issuers, it helps identify potential terrorism financing risks at onboarding or during card use, including situations where a card is settled by an unrelated third party. The indicators support the issuer’s assessment of whether activity gives rise to a suspicion requiring an STR or other appropriate reporting.

End to End AML Compliance Support in Singapore

National Risk Assessments Applicable to Non-Bank Credit Card Issuers in Singapore

Singapore publishes formal assessments of where its money laundering, terrorism financing and proliferation financing risks sit, and MAS Notice 626A requires NBCCs to fold the findings into their own risk assessment.

Money Laundering National Risk Assessment Singapore 2024

The national money laundering assessment gives non-bank credit card issuers their own section and places them in the lower risk band. It records a moderate ML threat but low vulnerability, because restrictions on cash payments, cash access and credit balances make a card a poor laundering vehicle, and it notes that the products are used mainly by residents and certain corporate customers. An issuer should carry these findings into its sector risk assessment.

Terrorism Financing National Risk Assessment 2024

The terrorism financing assessment concentrates on banks, remittance and payment channels rather than on card issuers, but an issuer is not exempt. It must apply the assessment’s typologies, such as small value transfers and the misuse of third parties, when it screens an applicant and reviews how a card is being used.

Proliferation Financing National Risk Assessment and Counter PF Strategy 2024

This assessment points to sanctions evasion, the abuse of legal persons and dual-use trade as the leading proliferation routes. For card issuers, the exposure is largely indirect, through a corporate cardholder with an opaque structure, which is why beneficial ownership work and sanctions screening at application carry the proliferation weight.

Environmental Crimes Money Laundering National Risk Assessment (May 2024)

An examination of how proceeds from environmental crime, spanning the illegal wildlife trade and illegal logging, get laundered. It rates banks and remittance agents as the high-risk sectors, and its bearing on card issuers is slight, arising only where a corporate cardholder’s funds may come from such activity.

Money Laundering and Terrorism Financing Risk Assessment of Legal Persons (2024)

This assessment marks companies as high risk for misuse and shows them producing a disproportionate share of suspicious transaction reports. It bears on card issuers whose cardholders include companies, for example on a corporate card programme, and it reinforces the duty to look through to the natural persons who own or control a corporate cardholder.

Virtual Assets (Digital Payment Tokens) Risk Assessment (2024)

This assessment reviews Singapore’s exposure to virtual asset activity. Its bearing on NBCCs is narrow, since a non-bank issuer does not deal in digital payment tokens, but it informs the attention an issuer pays to a cardholder whose repayments are linked to token activity.

Non-bank credit card issuer sector ML/TF risk snapshot

Money laundering: lower risk band, with a moderate ML threat but low vulnerability, because a card blocks cash placement and limits cash access (ML NRA 2024, chapter 7.13).

Main threat to manage: fraud, where a card is created with a stolen or false identity or card details are misused, met by application screening and fraud monitoring (ML NRA 2024, chapter 7.13).

Customer base: mainly Singapore residents and certain corporate customers, such as those in the tourism sector (ML NRA 2024, chapter 7.13).

Proliferation and terrorism financing: largely indirect, through a corporate cardholder with opaque ownership (PF and TF NRAs 2024).

Sector-Specific Guidance Applicable to Non-Bank Credit Card Issuers in Singapore

This is the core of a card issuer’s obligations. MAS supervises credit card and charge card licensees and issues the notices and guidance they must follow. The material divides into common instruments that apply across financial institutions and the specific instruments written for the sector, led by MAS Notice 626A and its Guidelines.

Common Guidelines for Non-Bank Credit Card Issuers

These MAS instruments apply across financial institutions and shape how a card issuer designs its controls. They do not displace Notice 626A; they explain MAS’s supervisory expectations on themes such as source of wealth, transaction monitoring, misuse of legal persons, sanctions and audit.

The Financial Services and Markets Act 2022

The FSM Act 2022 is the statute through which MAS supervises and enforces AML/CFT/CPF across the financial sector, and it provides the section 16 power under which Notice 626A is made. It authorises the sanctions regulations card issuers screen against and confers MAS’s inspection and direction powers. With an AML/CFT/CPF breach carrying a penalty of up to S$1 million, the Act is the enforcement backbone behind the notice.

Circular AMLD 01/2018: Use of MyInfo and CDD for Non Face to Face Business Relations

This circular accepts the Government’s MyInfo service as a reliable and independent source of cardholders’ core identity data. NBCCs onboarding a MyInfo user, the norm where cards are applied for online or in an app, can verify from that data instead of collecting documents afresh, subject to the circular’s safeguards for the impersonation risk that arises where MyInfo is not used, a risk that matters given identity fraud is the sector’s chief threat.

Circular AMLD 01/2022: Non Face to Face Customer Due Diligence Measures

This circular sets MAS’s expectations for onboarding without face-to-face contact, which is how nearly every card application is taken. It warns that a video or selfie check alone can fall short, urges a second independent channel for high-risk applicants, and expects the onboarding technology to be assessed by the firm and signed off by its board and senior management, a discipline that also blunts identity fraud.

Circular AMLD 02/2023: ML/TF Risks in the Wealth Management Sector

Written for wealth management, this circular reaches NBCCs only at the edges, where they serve a high net worth cardholder or a corporate customer with layered ownership. Even so, its themes carry over: stronger board oversight, a review of due diligence and quality assurance, seeing past holding vehicles to the true beneficial owners, and treating a customer who withdraws rather than answer questions as a reason to consider a report.

Circular AMLD 08/2024: Establishing the Sources of Wealth of Customers

This circular explains the steps a firm takes to establish a customer’s source of wealth before a relationship opens. For card issuers, it matters most for a high limit or corporate card. The issuer should take reasonable steps to establish the source of wealth, corroborate it under the tests of materiality, prudence and relevance, and escalate what it cannot substantiate.

Circular AMLD 05/2026: Risk Proportionate Source of Wealth Establishment

A circular that recalibrates how far source of wealth work should go. MAS wants the efforts to be effective, efficient and proportionate to risk, so ordinary cardholders are not burdened. NBCCs should concentrate corroboration on high limit or high-risk accounts, spare low-risk customers repeated requests, and keep escalation for genuine red flags.

Circular AMLD 11/2023: Ensuring Effective Detection of Sanctions Related Risks

MAS requires firms to identify and control sanctions risk, including unilateral sanctions from other jurisdictions. The board owns the risk appetite, and the circular sets out a lookback review after a designation. For card issuers, the practical effect is disciplined screening of cardholders and connected parties, and a review of live cards when a name is listed.

Circular AMLD 12/2024: Audit of AML/CFT Policies, Procedures and Controls

This circular is about the independent audit that constitutes a firm’s third line of defence. NBCCs must run an audit function that tests whether their AML/CFT/CPF controls actually work, staff it with the right expertise, give priority to high-risk areas such as onboarding and fraud monitoring, and benchmark against industry best practice.

Strengthening AML/CFT Controls on Misuse of Legal Persons and Complex Structures (August 2023)

Drawn from inspection work, this MAS paper describes firms that let troubling flows run through trusts, foundations and layered corporate structures. Its case studies expose failures to establish the true beneficial owner. Card issuers running corporate card programmes should measure themselves against it and be sure they have traced the natural persons behind a corporate cardholder.

AML/CFT Supervisory Expectations from Recent Inspections (October 2024)

Drawn from its recent inspections, this paper groups MAS’s expectations under five headings: reading multiple nationalities and investment migration links as risk factors, catching document red flags, testing whether a customer’s source of wealth stands up, backing a report or an exit with real mitigation, and sharing customer information across business lines. Each bears on how an issuer onboards and reviews a card.

Best Practices in Relation to Risks in Wealth Management (May 2025)

An industry paper for firms serving wealthy customers, gathering case studies on private investment companies, trusts and remote onboarding. Its reach into card issuers is limited to the occasional high net worth or complex corporate cardholder, but where an adviser or bank sits alongside, the issuer must still meet its own due diligence duties on the customer and its beneficial owners.

Effective Practices to Detect and Mitigate the Risk from Misuse of Legal Persons (June 2019)

An MAS paper on defending against shell and front companies across the customer lifecycle. It sets out multi-factor risk assessment, red-flag lists, network link analysis and staff training, and stresses that a single red flag is rarely conclusive. Token providers onboarding corporate customers should weigh several factors together, blending company registry checks with on-chain analysis, before acting.

Guidance for Effective AML/CFT Transaction Monitoring Controls (September 2018)

This paper draws together MAS’s inspection-based expectations for transaction monitoring. Card issuers already run sophisticated fraud monitoring, so the guidance is applied by extending that discipline to ML/TF/PF, tuning what to look for, keeping data clean and recording how alerts are handled across card spend and repayment.

Guidance to Capital Markets Intermediaries on Enhancing AML/CFT Frameworks and Controls (January 2019)

Written for capital markets intermediaries, this MAS guidance on governance, risk awareness and execution binds card issuers directly only where the same group also holds a capital markets services licence. For other issuers, it is persuasive good practice on board accountability, the three lines of defence and how a firm resourced its AML/CFT/CPF programme.

Guidelines on Risk Management Practices, Internal Controls (July 2024)

A prudential guideline describing what MAS looks for in a firm’s control environment and its business process controls. It touches customer due diligence only lightly and defers to the AML/CFT/CPF notices for the detail, so for card issuers it supplies the internal controls scaffolding, from segregation of duties to management reporting, around which the AML/CFT/CPF programme is built rather than a source of AML duties itself.

Guidelines on Provision of Digital Advisory Services (October 2018)

A conduct guideline covering digital and robo-advisory services. It touches NBCCs only where they offer automated advice through a digital platform. Its AML/CFT/CPF relevance is slim: the reminder that a remote channel still needs adequate ML/TF/PF controls and must manage the impersonation risk of onboarding a customer who is never met in person.

Sound Practices to Counter Proliferation Financing (August 2018)

Drawing on MAS’s thematic reviews, this paper addresses proliferation financing tied to DPRK and Iran sanctions evasion. It sets out how firms should strengthen controls, watch high-risk customers and counterparties, and recognise typologies such as shell companies with nominee directors. It reaches card issuers whose corporate cardholders may carry links to high-risk jurisdictions.

Strengthening Financial Institutions' CFT Controls (May 2023)

Drawing on an industry survey, this MAS information paper is about countering the financing of terrorism. It restates the duty to freeze and report designated party assets and sets expectations for screening, escalation and prompt, good quality reporting, each of which card issuers apply to their cardholders and their connected parties.

Specific Guidelines for Non-Bank Credit Card Issuers

These are the instruments written for the sector. Two of them, MAS Notice 626A and its Guidelines, are the rulebook card issuers live by, so they are covered in full below. The remaining notices apply only where issuers also carry on payment services.

MAS Notice 626A on Prevention of Money Laundering and Countering the Financing of Terrorism, Credit Card or Charge Card Licensees

Notice 626A is the principal binding AML/CFT/CPF notice for credit card and charge card licensees. It applies to persons licensed under section 57B of the Banking Act 1970 and sets out the AML, CFT and CPF requirements applicable to the sector. The notice operates alongside its accompanying guidelines, which explain MAS’s supervisory expectations and how licensees should implement the requirements. The 2025 amendments to the AML/CFT notices also addressed proliferation financing risk assessments and related controls across the financial sector.

The Notice requires a licensee to identify, assess and understand its money laundering and terrorism financing risks across its customers, relevant jurisdictions, products, services, transactions and delivery channels, and to apply a risk-based approach. Its risk assessment must be documented and supported by appropriate policies, controls and governance. The framework also requires attention to new products, practices and technologies where these may affect ML, TF and PF risks.

Customer due diligence is central to the framework. A licensee must not maintain anonymous or fictitious name accounts and must conduct CDD when establishing business relations, where there is suspicion of money laundering or terrorism financing, or where the licensee has doubts about previously obtained customer identification information. It must identify and verify the customer using reliable and independent sources, identify persons acting on the customer’s behalf and, where relevant, connected parties and beneficial owners. For legal persons and legal arrangements, beneficial ownership and control must be established using the applicable identification requirements.

The Notice applies a risk-based approach to ongoing customer management. Simplified measures may be used only where the relevant conditions and lower-risk circumstances are established, while enhanced due diligence applies where high risks are identified, including relevant politically exposed persons and high-risk jurisdictions or situations. Enhanced measures may include senior management approval, establishing source of wealth and funds, and enhanced ongoing monitoring. A licensee may rely on an eligible third party for specified CDD elements where the requirements are met but remains responsible for compliance with its obligations.

The remaining requirements complete the AML, CFT and CPF framework. The Notice covers record keeping, suspicious transaction reporting, internal policies and controls, compliance arrangements, independent audit and training. Its requirements on transfers and other specified activities apply according to the scope of the relevant provisions. Suspicious transactions are reported to the suspicious transaction reporting office, while the licensee must also observe the applicable tipping-off restrictions under the CDSA. The 2024 national risk assessment specifically confirms that NBCC issuers are subject to Notice 626A requirements covering CDD, record keeping and suspicious transaction reporting.

Guidelines to MAS Notice 626A (the primary guidance for card issuers)

The Guidelines to Notice 626A are the primary guidance card issuers work with, and they are given the fullest treatment here. They are dated July 2025, and their chapters mirror the paragraphs of the Notice, so NBCCs can read each obligation beside its explanation. They are guidance, not binding rules, yet MAS makes clear that how far a firm follows them can shape its overall view of the firm, including how well its board and senior management exercise oversight, so in practice they serve as the benchmark issuers are measured against.

The Guidelines open with the sector’s risk profile, which is lighter than most because of the product itself. A credit card resists laundering: a cardholder cannot load illicit cash onto it, cash access is capped, and credit balances are restricted, so the placement and integration stages are structurally blocked. The Guidelines confirm that proliferation financing is treated as part of money laundering throughout. They set out the accountability model, with the board and senior management answerable for AML/CFT/CPF effectiveness, supported by the three lines of defence. They acknowledge that fraud controls and AML controls overlap in this sector.

On the risk-based approach, NBCCs must assess their money laundering and terrorism financing risk not only account by account but on an enterprise-wide basis, taking into account the products, channels and their customer types, and including overseas operations where it is part of a financial group. The enterprise-wide assessment must be approved by senior management, should combine qualitative and quantitative analysis, must incorporate the findings of Singapore’s national risk assessments, and should be refreshed when a material change occurs, such as launching a new card product or a digital wallet.

The customer due diligence chapter is the longest, and it is written for a business that onboards almost entirely at a distance. It explains identification and verification of the cardholder from reliable and independent sources, how to treat a person acting for the customer, connected parties and beneficial owners, and it confirms the widely used benchmark that a beneficial owner is generally a natural person who owns more than 25% of an entity. Because applications are taken online, it gives close attention to non-face-to-face onboarding and the measures that counter impersonation, the same discipline issuer uses against identity fraud, and it explains the additional checks for a corporate card programme.

The enhanced due diligence chapter sets out who is a politically exposed person under the FATF standard, and it separates two ideas that are easily confused, source of wealth and source of funds: source of wealth is where the customer’s whole body of wealth came from, while source of funds is the origin of the money settling the card. NBCCs should corroborate this in proportion to risk and apply enhanced due diligence where a PEP, a complex structure, a high-risk jurisdiction or an unusual pattern of spend warrants it, with senior approval and closer monitoring. Screening guidance required cardholders and connected parties to be screened, and sanctions hits to be frozen or escalated without delay.

The remaining chapters complete the picture. Reliance is distinguished from outsourcing, where issuers keep responsibility for ongoing monitoring; the chapters on bearer negotiable instruments, correspondent accounts and wire and value transfers explain the information a qualifying transfer must carry. Record keeping, suspicious transaction reporting, for which the general standard is no later than five business days after suspicion is established, and the chapters on the compliance officer, audit and training complete the operational detail. A section on proliferation financing directs NBCCs to screen against the latest United Nations Security Council lists and to freeze without delay, and the Guidelines stress that card issuers’ mature fraud systems are an asset they should turn to AML/CFT/CPF ends.

Two threads run through the Guidelines and deserve emphasis for this sector. The first is ongoing monitoring: issuers must keep their due diligence current and watch card activity for patterns that do not fit the cardholder, from a sudden change in spend to settlement by an unrelated third party and escalate what it cannot explain. The second is the corporate card programme, where a single agreement can place cards with many employees; the Guidelines expect issuers to identify the corporate customer and its beneficial owners, to understand the programme’s purpose, and to set controls proportionate to its size and reach. Read together, the chapters turn a short notice into a working programme NBCCs can run day to day, in which onboarding, screening, monitoring and reporting each have a defined place.

MAS Notice PS N01 (Specified Payment Services)

Notice PS N01 is the AML/CFT/CPF notice governing licensed payment service providers under the Payment Services Act. It applies to card issuers only where the same firm also holds a payment services licence and carries on a specified payment service, such as an account issuance or money transfer service. For that activity, PS N01 applies in place of Notice 626A, with its own thresholds and transfer rules; for the firm’s card business, Notice 626A governs.

MAS Notice PS N10 (Exempt Payment Service Providers)

Notice PS N10 sets the AML/CFT/CPF requirements for persons exempt from holding a payment services licence, such as issuers that provide a payment service under an exemption. It reaches NBCCs only in that narrow case, applying a scaled set of customer due diligence, screening and reporting duties to the exempt activity while the card business remains under Notice 626A.

Why a credit card is a weak laundering vehicle

The sector’s low money laundering risk comes from the product itself. The table below sets out how a credit card blocks each stage of laundering, and where the real risk, fraud, lies.

Stage or feature	Why a credit card resists laundering
Placing cash	A cardholder cannot load illicit cash onto a credit card, so the placement stage of laundering is blocked at the outset
Getting cash out	Limits on cash advances and cash access cap how much value can be taken back out as currency
Credit balances	Restrictions on holding credit balances stop the card being used as a store of value
Integration	The amounts that can be moved are limited, so a card is a poor channel for reintegrating large sums
The real risk	Fraud, where stolen or false identities create cards or card details are misused, met by application screening and fraud monitoring

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Allied Laws Applicable to Non-Bank Credit Card Issuers in Singapore

These statutes are not primarily AML instruments, but each supports the regime: some license and govern card issuers, others give investigators their powers, and create the predicate offences and proliferation controls an issuer screens against.

The Banking Act 1970

The statute that provides the licensing and regulatory framework for credit card and charge card businesses. Under Part 8, NBCCs must be licensed to carry on the business of issuing credit cards or charge cards in Singapore, with section 57B empowering MAS to grant the license subject to conditions or restrictions. The Act also gives MAS supervisory powers to issue directions, obtain information, and inspect and investigate their business. These provisions provide the statutory foundation for MAS’s regulation of non-bank card issuers, alongside the AML, CFT and CPF requirements in Notice 626A. l

The Companies Act 1967

Singapore’s general company law statute. What matters for AML is its register of registrable controllers’ regime, mirrored in a central ACRA register, which NBCCs rely on and verify when they identify the controllers of a corporate cardholder.

The Securities and Futures Act 2001

The Securities and Futures Act reaches card issuers where the group’s activity extends into capital market products, so it may take on a capital markets licence and the corresponding notice for that activity. It marks the line between the card issuing regime and the securities regime a group can straddle.

The Monetary Authority of Singapore Act 1970

The Act that establishes MAS as the country’s central bank and integrated financial regulator. It is where MAS draws the authority to supervise card issuers and to issue the AML/CFT/CPF notices, Notice 626A among them, that the sector must follow.

The Prevention of Corruption Act 1960

Singapore’s principal anti-corruption law. Because corruption is a predicate offence for money laundering, the proceeds of offences under it are part of what NBCCs look for in PEP and source of funds checks on a high-limit or corporate card, and its presumption on unexplained assets reinforces scrutiny where a cardholder’s means cannot be explained.

The Criminal Procedure Code 2010

The procedural code that arms investigators with powers of production, search and seizure. Served with a production order, or an order relating to a card account, card issuers must comply, preserve their records and avoid tipping off, which is how an AML investigation reaches into the card.

The Strategic Goods (Control) Act 2002

Governs the transfer and brokering of strategic and dual-use goods, the proliferation financing nexus card issuers screen for. Its brokering controls fall away only where a person’s sole role is to provide financing or a financial service, which signals exposure where a corporate cardholder’s business touches such trade.

The Biological Agents and Toxins Act 2005

A predicate offence in the weapons of mass destruction, outlawing the non-peaceful use, production, acquisition or transfer of scheduled biological agents and toxins. For card issuers, it is one of the offences their proliferation financing screening watches for, engaged where a cardholder connects to prohibited biological weapon activity.

The Chemical Weapons (Prohibition) Act 2000

Singapore’s domestic law giving effect to the Chemical Weapons Convention, an offence to use, develop, acquire or transfer chemical weapons, directly or through a go-between. It sits behind the proliferation financing checks card issuers run on their cardholders.

Miscellaneous Laws and Regulations Applicable to Non-Bank Credit Card Issuers in Singapore

These national strategies, committee reports and typologies set the direction of Singapore’s regime, and the public-private partnership card issuers operate within. They carry no binding force, but they direct how MAS supervises and supply many of the typologies issuers build into their screening.

National Anti Money Laundering Strategy 2024

Singapore’s national AML blueprint, built on the pillars of Prevent, Detect and Enforce. NBCCs sit within the Prevent pillar, where MAS commits to risk-based supervision and to the beneficial ownership transparency an issuer relies on for due diligence on a corporate cardholder.

National Strategy for Countering the Financing of Terrorism 2024

Issued alongside Singapore’s 2024 terrorism financing national risk assessment, the strategy sets out Singapore’s national approach to countering terrorism financing across five areas: coordinated risk identification, robust legal and sanctions frameworks, a capable regulatory regime, effective enforcement and international cooperation. FOR NBCCs, it provides the broader national policy context for understanding and strengthening its terrorism financing risk management and controls.

National Asset Recovery Strategy 2024

Singapore’s strategy for tracing, restraining, confiscating and recovering criminal assets, with a focus on strengthening the country’s asset recovery framework and international cooperation. For NBCCs, its relevance is indirect as the issuer may need to cooperate with competent authorities.

Singapore Law Enforcement Strategy to Combat Money Laundering (October 2024)

A combined strategy of Singapore’s money laundering investigation agencies that identifies focus areas and key actions and relies on information flowing both ways with financial institutions. It frames the enforcement backdrop that NBCCs support through their reporting on suspicious applications and card use.

Inter Ministerial Committee on Anti Money Laundering Report (October 2024)

The review was held in the aftermath of a large money laundering case, proposing measures on the misuse of corporate structures, gatekeepers’ duties and stronger information sharing. Its themes reach a card issuer running corporate card programmes, and it marks the firmer supervisory stance the wider sector now sits under.

Legal Persons: Misuse Typologies and Best Practices (2018)

A typologies paper on the ways companies and partnerships are misused, giving card issuers the red flags for beneficial ownership and corporate cardholder checks. It is useful where an issuer runs a corporate card programme for a company with an opaque owner.

International Standards Applicable to Non-Bank Credit Card Issuers in Singapore

Singapore’s regime is built to meet the FATF standards, and Notice 626A tracks them. These instruments are the least sector-specific of all, yet they explain why the domestic rules look the way they do and hand a card issuer the typologies and methods supervisors expect it to track.

The FATF Recommendations (updated June 2026)

The 40 Recommendations are the global AML/CFT and CPF standard behind every obligation on card issuers, from customer due diligence and beneficial ownership to the travel rule, politically exposed persons and suspicious transaction reporting.

Mutual Evaluation Report of Singapore (May 2026)

In the 2026 evaluation, the FATF and the Asia/Pacific Group appraise how well Singapore’s regime functions practically. It frames supervisory expectations across the financial sector, including the proportionate expectations placed on card issuers.

Methodology for Assessing Technical Compliance and Effectiveness (updated June 2026)

The yardstick the FATF uses to test technical compliance with the Recommendations and how effective a country’s system proves in practice. It fixes the standard by which Singapore, and by extension its card issuers, are measured, and it informs MAS’s supervisory expectations.

FATF Guidance on Politically Exposed Persons (Recommendations 12 and 22, 2013)

It sets out how a firm identifies politically exposed persons and subjects them to enhanced due diligence: senior sign off, establishing source of wealth and funds, and closer ongoing monitoring, which card issuers apply to a PEP cardholder.

Guidance on Beneficial Ownership of Legal Persons (March 2023)

Guidance issued under the revised Recommendation 24 on how to obtain and verify beneficial ownership information, shaping how NBCCs pin down the beneficial owners of a corporate cardholder.

Best Practices on Beneficial Ownership for Legal Persons (October 2019)

A collection of country best practices for keeping beneficial ownership information adequate, accurate and up to date, backing card issuers’ use of registries and multiple sources when it identifies the controllers of a corporate cardholder.

FATF Guidance on Counter Proliferation Financing (February 2018)

Guidance on carrying out the financial provisions of Security Council resolutions against weapons of mass destruction proliferation, under which card issuers must screen and freeze without delay in line with Recommendation 7.

Guidance on Proliferation Financing Risk Assessment and Mitigation (June 2021)

Sets out how a firm should gauge and manage proliferation financing risk after Recommendations 1 and 2 were amended to fold it into the sector-wide risk-assessment duty.

Guidance on Digital Identity (March 2020)

Guidance for card issuers to judge whether a digital identity system is reliable and independent enough for customer due diligence under a risk-based approach, a central question for a business that onboards its cardholders online.

Artificial Intelligence and Deepfakes: Impacts on ML/TF/PF

A forward-looking FATF scan of how artificial intelligence and deepfakes threaten preventive systems, for example, synthetic identities defeating the remote onboarding of a cardholder, alongside AI’s uses in screening and fraud monitoring.

Summary of Key Instruments

The table below distils the instruments an NBCC relies on most, what type each is, whom it binds, and the core obligation it places on the issuer. A concise reference to keep to hand, not a substitute for the fuller sections above.

Instrument	Type	Binds	Core obligation for a card issuer
CDSA 1992	Statute	Everyone	Report suspected criminal proceeds; do not tip off
TSOFA 2002	Statute	Everyone	Do not deal in terrorist property; screen and report
FSM sanctions regulations (DPRK, Iran)	Regulations	All FIs	Freeze designated persons’ assets without delay
MAS Notice 626A	Notice (binding)	Card issuers	Risk-based CDD, transfer rules, records, STR
Guidelines to Notice 626A	Guidelines	Card issuers	Primary guidance; how to meet the Notice
Notice PS N01 / PS N10	Notices	Payment services	Apply only where the firm also carries on payment services
Banking Act 1970 (s 57B)	Statute	Card issuers	Licence the issuer; frame cash and balance limits
FATF Recommendations	Standard	Everyone	The global standard behind the domestic rules

Conclusion

For non-bank credit card issuers in Singapore, the anti-money laundering and counter-terrorism financing framework is shaped by the characteristics of a product with limited cash-in and cash-out functionality. Criminal statutes establish money laundering and terrorism financing offences and reporting obligations; the sanctions framework requires relevant screening and freezing measures; and MAS Notice 626A, together with its guidelines, translates these requirements into risk-based customer due diligence, transfer controls, enhanced measures for high-risk customers, and suspicious transaction reporting. Because credit cards offer limited scope for direct cash movement, an issuer’s controls place significant emphasis on who holds the cards, how the account is used and whether the identity behind it is genuine.

The instruments interlock. An issuer’s risk assessment should take account of relevant national risk assessments; its customer due diligence and transfer controls are governed primarily by Notice 626A and its guidelines; its licensing framework comes from the Banking Act; and its sanctions and proliferation financing controls are supported by the applicable sanctions legislation and regulations, alongside the FATF standards. For this sector, the practical challenge is to connect established fraud, identity and transaction monitoring capabilities with AML, CFT and CPF controls, allowing these systems to reinforce one another while addressing their distinct risks.

Anti-Money Laundering Services & Compliance Solutions

Frequently Asked Questions

Which MAS notice applies to non-bank credit card issuers?

MAS Notice 626A is the anti-money laundering and countering the financing of terrorism notice for credit card and charge card licensees, issued under section 16 of the Financial Services and Markets Act 2022 and applying to firms licensed under section 57B of the Banking Act 1970. It is read together with the Guidelines to Notice 626A, which explain each obligation in turn.

Why are credit cards considered low money laundering risk?

Because the product resists laundering. A cardholder cannot load illicit cash onto a credit card, cash access is capped, and credit balances are restricted, so the placement and integration stages are structurally blocked. Singapore’s 2024 assessment reflects this, rating the sector as low risk. The sharper threat is fraud, where cards are created with stolen or false identities or card details are misused.

What customer due diligence must card issuers perform?

Under Notice 626A, an issuer performs customer due diligence when it establishes business relations with a cardholder, when it suspects money laundering or terrorism financing, or when it doubts information it holds. It identifies and verifies the cardholder from reliable, independent sources, identifies any person acting for them and the connected parties and beneficial owners of a corporate cardholder, and screens against sanctions lists and for politically exposed persons.

How does AML relate to a card issuer's fraud controls?

They overlap and reinforce each other. The identity checks and monitoring that stop card fraud are the same disciplines that detect money laundering and terrorism financing, and MAS expects card issuers to turn their mature fraud systems to AML/CFT/CPF ends. In this sector, strong onboarding and transaction monitoring do double duty against fraud and against laundering.

Are non-bank credit card issuers regulated by MAS?

Yes. A non-bank credit card issuer holds a credit card or charge card licence under section 57B of the Banking Act 1970 and is supervised by the Monetary Authority of Singapore, which issues Notice 626A and its Guidelines and inspects the sector on a risk-based approach. Most credit cards in Singapore are issued by banks; the non-bank issuers are a small, separately licensed group.

When must a card issuer file a suspicious transaction report?

Whenever it has reasonable grounds to suspect money laundering or terrorism financing. The report goes to the Suspicious Transaction Reporting Office, generally within five business days of forming the suspicion, and within one business day where sanctions are engaged, and the issuer must not tip off the cardholder. Our guide to STR red flags explains common triggers.

About the Author

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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.