At the IMAS 19th Regulatory Roundtable, held in partnership with Deloitte Singapore, members
discussed the growing complexity of financial crime risks and key AML/CFT compliance challenges.
Deloitte speakers highlighted MAS’ updated supervisory expectations, covering areas like enhanced
customer risk assessments, source of wealth, and identifying red flags. They also addressed
operational hurdles in AML/CFT compliance.

Breakout sessions revealed key insights, including the need for flexible document verification,
identifying tampered documents, and balancing new technology adoption with costs. Discussions
also emphasized the importance of internal training, clear guidance on Source of Funds/Source of
Wealth (SOF/SOW), and overcoming challenges with Ultimate Beneficial Owner (UBO) identification,
particularly in complex structures.

Key highlights:

• A walkthrough of MAS’ latest supervisory expectations – including enhanced customer risk
  assessments, source of wealth establishment, identification of material red flags, and holistic
  account monitoring
• Operational challenges in AML/CFT compliance – including siloed transaction reviews,
  limited resources, and technology gaps
• Red flag indicators specific to CMIs, such as complex offshore structures, unusual trading
  behaviours, and obscured beneficial ownership
• Case studies on enforcement actions and best practices to build strong compliance cultures
  and avoid penalties
• Practical strategies to improve consistency across the industry – from adopting a risk-based
  approach and interoperable systems to strengthening governance and audit functions

Findings from breakout groups discussion:

• The need for flexibility in document verification – including acceptance of alternative IDs,
  use of HR letters, and remote certifications based on risk
• Concerns over tampered documents and how to spot them (e.g. font inconsistencies, audit
  trail gaps)
• Practical trade-offs between adopting new technologies and managing costs, with AI, RPA,
  and blockchain offering future promise but limited current uptake
• The importance of internal training, clear guidance on SOF/SOW, and strong vendor
  oversight to maintain compliance integrity
• Privacy hurdles, cross-border discrepancies, and challenges in UBO identification – especially
  with family offices and complex structures