Empowering Singapore’s Financial Institutions through COSMIC Power SEA View, Article XIV: October 2021

Hogan Lovells

Hogan Lovells

[co-author: Audrey Koh]

After a summer hiatus, we return with a warning of imminent AML controls; a trend we witness across the region. On 1 October 2021, the Monetary Authority of Singapore (“MAS”) published a Consultation Paper on the FI-FI Information Sharing Platform. On this new digital platform, MAS plans to introduce a new regulatory framework for Financial Institutions (“FI”) to share information with each other to reduce and prevent financial crimes, such as money laundering (“ML”), terrorism financing (“TF”) and proliferation financing (“PF”).

The birth of COSMIC

The new secured digital platform, titled 'Collaborate Sharing of ML/TF Information & Cases' (“COSMIC”), is a welcome addition to the financial sector. It provides quicker detection of financial crimes and provides greater security to legitimate customers and FIs respectively.

With the COSMIC platform, FIs will be able to collaborate effectively with each other during the customer due diligence process and better identify potentially suspicious activities which involve their customers. This is a departure from previous practice, whereby FIs were not allowed to forewarn and tip-off each other about questionable transactions.

COSMIC is intended to fill the information gap between FIs and restrict financial criminals from taking advantage of this lacuna to enter into illicit transactions. Additionally, it will result in the enhanced quality of suspicious transaction assessments conducted by FIs.

The COSMIC platform will allow FIs to share information when detecting key ML,TF or PF risks in three different modes. The three different modes are by alerting, requesting and providing information. To illustrate, FIs will alert, provide and request from other FIs if they detect that their customers are involved in the misuse of legal persons (such as the setting up of shell companies to launder illicit proceeds and disguise the origins), trade-based ML and PF. FIs should ensure that information is not shared injudiciously such that it will raise concern about the confidentiality, security and privacy of customers.

With the mass migration of information, MAS intends to introduce a legislative framework to govern the sharing of risk information on COSMIC. This will prevent the misuse of information obtained from COSMIC. FIs, including the major banks in Singapore will be required to put in place robust measures to prevent the unauthorised use and disclosure of COSMIC information. MAS will step in to ensure that FIs comply with these requirements and, if necessary, take action against errant FIs. It will be imperative that compliance with new legislative requirements under the COSMIC platform is adhered to by FIs.

Lessons from the Pandora Papers

The recent Pandora Papers leak highlights the importance of the need to consistently refine Singapore’s rigorous anti-money laundering and countering the financing of terrorism (“AML/CFT”).

The Pandora Papers have revealed the secret wealth and hidden dealings of international entities, political individuals and corporations globally, and their involvement in potentially shady and unsavoury dealings. With the implementation of COSMIC, the information gap will be diminished, and corporate entities will find it more difficult to mask any wrongdoings from MAS and FIs by taking advantage of the loopholes in the law to manage trusts and shell companies for their clients.

With MAS pioneering the COSMIC platform and FIs assuming key roles in detecting suspicious activities, we can expect positive changes in the AML/CFT space through timely intervention to stop financial crimes.

The consultation period for COSMIC closes on 1 November 2021.

SEA View

Since April 2019, our periodical has featured investigation, compliance, and regulatory developments in Southeast Asia (SEA). Each article showcases our insights on SEA and beyond, liaising with our extensive expertise around the globe. We draw on the firm's market leading practices, including our assembled Global Regulatory team, to lead clients' businesses through challenges encountered in and out of SEA. Find our previous insights here.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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