The Financial Services and Markets Act 2022 was amended earlier this year to, among other things, establish a new electronic information sharing system, Collaborative Sharing of money laundering (“ML“) / terrorism financing (“TF“) Information & Cases (“COSMIC“). COSMIC enables the secure disclosure, publication and sharing of risk information by prescribed financial institutions (i.e. banks in Singapore or financial institutions (other than a bank) that are prescribed under subsidiary legislation) (“prescribed FIs“) for the prevention and detection of ML, TF and proliferation financing (“PF“).
As a start, COSMIC will focus on three key financial crime risks in commercial banking: (i) misuse of legal persons; (ii) misuse of trade finance for illicit purposes; and (iii) PF. A prescribed FI must comply with certain requirements when sharing information on COSMIC. MAS proposes setting these out in a new Notice (“COSMIC Notice“) and issued a consultation paper to seek feedback on this. Banks in Singapore are subject to AML/CFT requirements under MAS Notice 626 on the Prevention of Money Laundering and Countering the Financing of Terrorism – Banks (“MAS Notice 626“). MAS also seeks feedback on amendments to MAS Notice 626 to clarify the relationship and interaction between certain requirements in the COSMIC Notice and the existing AML/CFT requirements in MAS Notice 626. Feedback should be submitted by 15 December 2023.
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