What types of anti-money laundering / countering the financing of terrorism (AML/CFT) risk mitigation measures should a provider of e-wallets and e-money comply with?
A person providing e-money issuance services under the Payment Services Act 2019 is subject to AML/CFT risk mitigation measures, in addition to specific risk mitigation measures relating to user protection, interoperability (fragmentation of payment solutions) or technology and cyber security risks, depending on the type of regulated activity conducted by the providers.
The AML/CFT risk mitigation requirements are set out in MAS Notice on Prevention of Money Laundering and Countering the Financing of Terrorism - Holders of Payment Services Licence (Specified Payment Services) (PSN01). Failure to comply with the requirements set out in the MAS Notice attracts a fine.
The MAS Guidelines to MAS Notice PSN01 on Prevention of Money Laundering and Countering the Financing of Terrorism – Specified Payment Services provide guidance on the requirements in the Notice.
The Notice requires, among other things, a person providing e-money issuance services to develop and put in place policies and procedures to assess the money laundering and terrorism financing ("ML/TF") risks presented by each customer. It must also assess the ML/TF risks on enterprise-wide level. This shall include a consolidated assessment of the payment service provider’s ML/TF risks that exist across all its business units, product lines and delivery channels. To assess the ML/TF risks presented by its customer, the service provider must conduct customer due diligence to identify and know its customers (including beneficial owners), conduct regular account review and monitor and report any suspicious transaction.