Stage four: the independent assessment

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The independent assessment is a report by an external party, usually an audit firm or a specialist consultancy, on the adequacy of the applicant's AML/CFT framework and, for DPT applicants, of its technology risk and custody arrangements. MAS specifies the scope and expects the assessor to test the framework in operation and not only on paper.¹ The report must be submitted before in-principle approval, which makes its timing the most common source of delay. An assessment commissioned when the policies are final takes two to four months. An assessment commissioned before the policies are final produces a qualified report and must be repeated.

Notes

MAS, Guidelines on Licensing for Payment Service Providers (PS-G01), section on the independent assessment of the AML/CFT framework for applicants, and the extended scope for DPT applicants following the 2024 amendments. ↩

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

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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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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.

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