#
[Sentinel.gi position] Singapore's payments AML/CFT posture rests on a tiered MAS Notice regime — Notice PSN01 for specified payment services and PSN02 for DPT service providers — under the Financial Services and Markets Act 2022, with fines up to S$1m per offence (plus S$100k/day continuing). Revisions effective 1 July 2025 formally incorporate proliferation-financing risk in line with FATF. Singapore is an FATF and APG member; the COSMIC platform enables FI information-sharing. 2025 enforcement (S$27.45m + S$960k) reflects intensified supervision ahead of the FATF mutual evaluation.
The commercial significance carried here is that the PSN01/PSN02 Notice penalty architecture sets the AML/CFT cost-of-compliance floor for payments and DPT operators across both bank and nonbank institutions. The Sentinel feed notes that Singapore is an FATF and APG member and operates COSMIC for FI information-sharing. This regime is the rulebook backdrop to the enforcement actions surfaced in W7 — the five-MPI PSN01 action and the S$27.45m nine-FI tranche — but the illicit-finance analysis of those actions is a FIM matter, not a WPM conclusion.
Further detail on the Sentinel feed is available via its source; WPM does not re-analyse illicit finance.
Outlook
The forward edge is the bedding-in of the 1 July 2025 proliferation-financing assessment requirement and the continued operation of COSMIC information-sharing, both of which raise the compliance floor for payments and DPT operators. The deeper illicit-finance trajectory is carried by FIM via the cross-monitor flags.
no periodic updates on record for this sub-brief
Sources and findings (5)
- T3sentinel.gi://flagright/psn01-enforcement-2025
- T?FIM (sentinel.gi) per-JID baseline profile — Singapore — Singapore operates a comprehensive statutory AML/CFT/CPF regime centred on MAS Notices, the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act, the 2024 AML and Other Matters Act, and the FSMA-based DTSP licensing regime; FATF/APG's 2026 MER found a competent, coordinated system with a well-resourced FIU but uneven risk-based enforcement outcomes.
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: regulatory-failure
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: enforcement-absence
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: capacity-deficit