https://www.globalgovernmentfintech.com/singapore-aml-whole-of-government-data-sharing-interface/

Singapore is to develop a ‘whole-of-government data-sharing interface’ to tackle money laundering amid ‘increasingly complex’ risks.

The plan is among the commitments in a ‘National Anti-Money Laundering (AML) Strategy’, jointly published by the Ministry of Finance, Ministry of Home Affairs and Monetary Authority of Singapore (MAS) on 30 October as part of ‘continuing efforts to maintain the effectiveness’ of the city-state’s AML efforts.

The strategy sets out a series of what are described as ‘risk-targeted actions to combat ML amidst rapidly changing risks and criminal typologies.’ These include the development of the data-sharing interface – which will be called the ‘National AML Verification Interface for Government Agencies Threat Evaluation’ (‘NAVIGATE’) – and the creation of an ‘AML sensemaking workgroup to oversee operations-technology and capability development across government agencies.’

NAVIGATE will allow agencies to ‘seamlessly screen against one another’s databases and expeditiously assess entities of concern for ML risks’, the 32-page document explains.

The new AML sensemaking workgroup, meanwhile, will oversee the government’s operational policies, data-sharing processes and capabilities in sensemaking. It will led by the Ministry of Home Affairs and Singapore Police Force, and include bodies including MAS and the Accounting & Corporate Regulatory Authority (ACRA).

Three-pillar strategy

The strategy’s publication comes eight years after Singapore published a national policy statement on money laundering/terrorism financing (ML/TF), as well as other risk assessments and reviews. These include a Money Laundering National Risk Assessment Report (NRA) 2024 published in June 2024.

Singapore faces ‘increasingly complex ML risks, in tandem with geo-political and macro-economic developments, the use of sophisticated structures and technological advancements,’ the strategy notes, reflecting the findings of the 126-page NRA.

The new strategy has three pillars overall: ‘Prevent’, to deter proceeds of crime from entering Singapore’s system and prevent the misuse of Singapore’s system by criminals; ‘Detect’, to identify illicit flows and activities and ensure timely and effective mitigation, disruption and enforcement actions, and ‘Enforce’, to take ‘firm and dissuasive’ actions against money-launderers.

These three pillars are supported by three inter-dependent elements: ‘whole-of-society’ coordination and collaboration; legal and regulatory developments; and international cooperation.

It concludes that the authorities will ‘continue to monitor and identify emerging and changing risks and take a risk-based and proportionate approach to implement measures that are targeted against the abuse of our system while remaining welcoming to legitimate businesses and investments in Singapore’.

From ISTRA to AC3N

At a government level, Singapore’s AML efforts are led by an AML/CFT steering committee, which comprises the permanent secretaries of the Ministry of Home Affairs and Ministry of Finance, as well as MAS’s managing director. This committee is supported by an AML/CFT inter-agency committee. There is also a risk typologies inter-agency group (RTIG), which is the main working level body tasked to review ML risks at the government level.

In addition, an ‘Inter-Agency Suspicious Transaction Report Analytics Taskforce’ (ISTRA) was formed in 2018 under the auspices of the RTIG, to facilitate the development, prioritisation and coordination of significant ML cases across agencies, including law enforcement and supervisory authorities.

ISTRA enabled ‘better identification of complex and sophisticated forms of ML activities by leveraging on data analytics for more focused detection of suspicious networks’ and ‘providing a channel for whole-of-government coordination to mitigate the risks arising from these suspicious networks’, the strategy notes.

But following a review by an inter-ministerial committee, whose 21-page report was published on 4 October, ISTRA has been replaced by AC3N (whose name stands for ‘AML Case Coordination and Collaboration Network).

‘With wider membership and higher level of oversight, AC3N allows for even more effective and coordinated investigative, supervisory and enforcement actions across agencies,’ the strategy states. ‘Through AC3N, sector supervisors will also gain deeper insights into risks affecting their specific sectors and drive risk-based supervisory efforts’.

COSMIC measures

The strategy includes reference to the ‘COSMIC’ platform (‘COllaborative Sharing of Money Laundering /TF Information & Cases’), which was co-developed by MAS and six major commercial banks. Launched earlier this year it was billed as the first ‘centralised digital platform’ to facilitate sharing of customer information among financial institutions to combat money laundering, terrorism financing (TF) and proliferation financing globally. It enables information to be shared among commercial banks in a structured format that should allow for seamless integration with data analytics tools globally

The strategy contains a commitment to ‘continued review of effectiveness of surveillance tools and information sharing mechanisms, including review of COSMIC.’ MAS plans to expand COSMIC in phases, with the initial phase to run for two years. A decision will then be taken whether to expand COSMIC’s coverage to more focus areas and financial institutions.

Among numerous legislative measures, reference is made to amendments to allow Singapore’s customs agency to share trade data with the Suspicious Transactions Reporting Office (STRO) to develop ‘richer’ financial intelligence on AML and similar risks. Provisions will come into force by ‘early’ 2025.

On the international front, there is an intention to ‘implement enhancements in [Singapore’s] legal framework to enhance Singapore’s ability to cooperate in ML cases.’

Singapore’s Mutual Assistance in Criminal Matters Act (MACMA) 2000 ‘will be amended to improve Singapore’s ability to provide and request for assistance in international criminal cooperation, including empowering Singapore LEAs [law enforcement agencies] to take statements from witnesses and suspects in relation to requests relating to foreign criminal investigations.’