简体 繁體 日本語 한국어 English Deutsch Français Italiano Español Português

Reporting in the group

Read the PDF edition (1 page)

Where a Singapore DPT licensee is part of a group, the firm must decide how much of an STR may be shared with affiliates. PSN02 requires group-wide information sharing for AML/CFT purposes, including sharing of information about customers and transactions needed for group risk management, subject to safeguards.1 The tipping-off offence and the confidentiality of the STR itself cut the other way. The accepted practice is to share the fact of a risk event and the resulting risk rating of the customer across the group. The existence and content of the STR stay with the Singapore compliance function and with those group officers who need to know for group risk management and are bound by equivalent confidentiality. The same applies in reverse when the Swiss affiliate has filed with MROS under Art. 9 AMLA, where Art. 10a AMLA restricts disclosure. Chapter VIII sets out a model protocol.

Notes

  1. MAS Notice PSN02, para. 15 (group policy), requiring group-wide programmes against money laundering and terrorism financing including policies and procedures for sharing information required for CDD and risk management, with adequate safeguards on confidentiality. ↩

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.

Setting up or expanding in Singapore?

SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For Hong Kong, our parallel site HongkongIQ.com offers the same practical guidance. For crypto and digital assets, dltreg.com covers legal, tax and fiduciary services. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.