MAS inspections
MAS supervises DPT licensees through off-site monitoring of returns and STR copies, through thematic reviews across groups of licensees and through on-site inspections of individual firms. An inspection begins with a notification letter and a request for documents. These are typically the risk assessment, the policies, the organisation chart, the compliance committee minutes, the STR register and the audit reports, together with a customer list from which the inspectors select a sample. The on-site phase involves interviews with the compliance officer, management and front-line staff, walk-throughs of the systems and detailed review of the sampled files. The inspection closes with a letter of findings. The letter classifies observations by severity and requires a remediation plan within a stated period.1
MAS's published findings from its DPT thematic inspections have identified recurring weaknesses. Risk assessments did not reflect the firm's actual business. Source-of-wealth corroboration for higher-risk customers was inadequate. Transaction-monitoring thresholds were set without analysis and never recalibrated. Travel-rule implementation for transfers to other VASPs was incomplete and transfers to unhosted wallets received insufficient scrutiny. STR filing was delayed and compliance functions were under-resourced relative to transaction volumes.2 Each of these maps onto a chapter of this Part. A firm that has read the paper and tested itself against each finding before the inspection has done most of what MAS will ask.
Notes
- MAS, Enforcement Monograph, 2018, and MAS Enforcement Reports, on the supervisory and enforcement process; MAS, Information Paper on AML/CFT controls of DPT service providers, summarising thematic inspection findings. ↩
- MAS, Information Paper on Strengthening AML/CFT Controls of Digital Payment Token Service Providers, sections on risk assessment, CDD, transaction monitoring and value transfers. ↩
For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.