Screening

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PSN02 requires the firm to screen customers, natural persons appointed to act, connected parties and beneficial owners against relevant lists at onboarding, on a periodic basis and when lists are updated.¹ The relevant lists are the United Nations Security Council consolidated list, the designations made in Singapore under the United Nations Act 2001 and TSOFA, MAS's own lists and such other lists as the firm's risk assessment makes relevant. Chapter VI deals with the sanctions content. The screening requirement is a hard-edged duty: a single unscreened beneficial owner is a notice breach whatever the outcome. Firms should screen before any transaction is executed. The one-hour delay in a customer's first trade is cheaper than a composition penalty.

For DPT firms screening has a second dimension that has no fiat equivalent: wallet screening. The Guidelines expect firms to screen counterparty wallet addresses against lists of addresses associated with sanctioned persons (the OFAC Specially Designated Nationals list has included addresses since 2018) and with known illicit activity, using blockchain-analytics tools.² A deposit from an address that a reputable analytics tool links to a sanctioned mixer or a hacked exchange is not a screening "hit" in the sanctions sense unless the address is itself designated. It is nevertheless a red flag that triggers enhanced monitoring and possibly a suspicious transaction report. Chapter VII addresses the choice and governance of analytics vendors.

Notes

MAS Notice PSN02, para. 6 (screening), read with para. 2 (definition of "connected party" and of the lists against which screening is required, including lists of designated persons under the United Nations Act and TSOFA). ↩
Guidelines to Notice PSN02, section on value transfers and on the use of blockchain analytics; MAS, Information Paper on Strengthening AML/CFT Controls of Digital Payment Token Service Providers, observations on wallet screening. ↩

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.

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Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

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