Consultation Paper on the FI-FI Information Sharing Platform for AML/CFT

23 Mar 2023 Legal Highlights

The Monetary Authority of Singapore ("MAS") recently published its Response to Feedback Received on the Consultation Paper on the Financial Institution ("FI") Information Sharing Platform for Anti-Money Laundering and Counter-Terrorism Financing ("AML/CFT"). This response clarifies the scope and operation of proposed secured digital platform called "Collaborative Sharing of Money Laundering and Terrorism Financing Information & Cases" ("COSMIC"), which is intended to enhance information exchange between FIs to more effectively detect and disrupt criminal activities. Six prescribed banks will participate on COSMIC in the initial phase, and MAS plans to progressively extend COSMIC to a wider segment of the financial sector and expand the key areas of focus in subsequent phases.


Participant FIs will share risk information with each other where a customer's unusual activities crosses the stipulated threshold criteria, and the participant FI knows or has reason to believe that another participant FI has the same customer or is linked to the customer's transaction. These obligations will apply in cases concerning former, current, and prospective customers of participant FIs. Participant FIs will also be conferred with statutory protection from civil liabilities, and carveouts from the Personal Data Protection Act 2012 and Banking Act 1970 will be made in relation to the sharing of information on COSMIC. MAS has cautioned that participant FIs should not rely solely on information obtained from COSMIC when making AML/CFT decisions, and that the sharing of information on COSMIC does not detract from their suspicious transaction reporting obligations under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992.


MAS' response may be accessed at the link here.


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