AML/CFT for all payment service providers

How are AML/CFT requirements applied to the various types of licensees?

MAS adopts a risk-based approach.

AML/CFT requirements are calibrated according to the degree of risks posed by each of the respective payment services.

For instance, a provider of payment services may pose higher ML/TF risks and will be subject to the full suite of AML/CFT requirement, whereas some providers of payment services that are assessed to be low risk may be subject to lesser requirements or exempted.

On a related note, all DPT service providers are subject to AML/CFT requirements under Notice PSN02. There are no DPT services that will be exempted from AML/CFT regulation.

According to MAS (FAQs)
last revised 31 March 2021

28.1 Where payment services activities may be abused for ML/TF, such risks should be appropriately mitigated.

28.2 The PS Act therefore imposes AML/CFT measures on persons carrying on a business in providing payment services that have been assessed to pose ML/TF risks, for example, persons carrying on a business of providing DPT services. Activities that pose low ML/TF risk, such as merchant acquisition services, are not regulated for AML/CFT purposes.