MAS Notice 314

24 April 2015
Last revised on 1 March 2022
(Refer to endnotes for history of amendments)

NOTICE TO DIRECT LIFE INSURERS

MONETARY AUTHORITY OF SINGAPORE ACT 1970

PREVENTION OF MONEY LAUNDERING AND COUNTERING THE FINANCING OF

TERRORISM – DIRECT LIFE INSURERS

1 INTRODUCTION

1.1 This Notice is issued pursuant to section 27B of the Monetary Authority of Singapore Act
1970 (“MAS Act”) and applies to all direct life insurers licensed under section 8 of the
Insurance Act 1966 (“IA”).
[MAS Notice 314 (Amendment) 2022]

1.2 The requirements of this Notice (other than those set out in paragraphs 13.3 to 13.9) shall
apply to a direct life insurer, only in relation to its insurance business concerned with life
policies but shall exclude the business of providing the reinsurance of liabilities under life
policies.

1.3 Except for paragraphs 4, 5, 13.6 and 13.7, this Notice shall take effect from 24 May 2015.
Paragraphs 4, 5, 13.6 and 13.7 shall take effect from 24 July 2015. MAS Notice 314 dated
2 July 2007 is cancelled with effect from 24 May 2015.

2 DEFINITIONS

2.1 For the purposes of this Notice -

“AML/CFT” means anti-money laundering and countering the financing of terrorism;

“Authority” means the Monetary Authority of Singapore;

“beneficial owner”, in relation to a customer of a direct life insurer, means the natural person
who ultimately owns or controls the customer or the natural person on whose behalf
business relations are established, and includes any person who exercises ultimate
effective control over a legal person or legal arrangement;
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 “business relations” means -

(a) the issuance of a life policy by the direct life insurer to; or

(b) the provision of financial advice by the direct life insurer to,

a person (whether a natural person, legal person or legal arrangement);

“CDD measures” or “customer due diligence measures” means the measures required by
paragraph 6;

“CDSA” means the Corruption, Drug Trafficking and Other Serious Crimes
(Confiscation of Benefits) Act 1992;
[MAS Notice 314 (Amendment) 2022]

“connected party” -

(a) in relation to a legal person (other than a partnership), means any director or any
natural person having executive authority in the legal person;

(b) in relation to a legal person that is a partnership, means any partner or manager 1;
and

(c) in relation to a legal arrangement, means any natural person having executive
authority in the legal arrangement;

“Core Principles” refers to the Core Principles for Effective Banking Supervision issued by
the Basel Committee on Banking Supervision, the Objectives and Principles for Securities
Regulation issued by the International Organisation of Securities Commissions, or the
Insurance Core Principles issued by the International Association of Insurance
Supervisors;

“customer”, in relation to a direct life insurer, means a person (whether a natural person,
legal person or legal arrangement) with whom the direct life insurer establishes or intends
to establish business relations including, in the case of a group life policy, the owner of the
master policy issued or intended to be issued;

“direct life insurer” means a direct insurer licensed under section 8 of the IA to carry on
life business as described in section 2(1) of the IA;

1 In the case of a limited liability partnership or a limited partnership

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“FATF” means the Financial Action Task Force;

“financial advice” means a financial advisory service as defined in section 2(1) of the
Financial Advisers Act 2001 or advising on corporate finance as defined in section 2(1) of
the SFA;
[MAS Notice 314 (Amendment) 2022]

“financial group” means a group that consists of a legal person or legal arrangement
exercising control and coordinating functions over the rest of the group for the application
of group supervision under the Core Principles, and its branches and subsidiaries that are
financial institutions as defined in section 27A(6) of the MAS Act or the equivalent financial
institutions outside Singapore;

“government entity” means a government of a country or jurisdiction, a ministry within such

a government, or an agency specially established by such a government through written
law;

“legal arrangement” means a trust or other similar arrangement;

“legal person” means an entity other than a natural person that can establish a permanent
customer relationship with a financial institution or otherwise own property;

“officer” means any director or any member of the committee of management of the direct
life insurer;

“partnership” means a partnership, a limited partnership within the meaning of the Limited
Partnerships Act 2008 or a limited liability partnership within the meaning of the Limited
Liability Partnerships Act 2005;
[MAS Notice 314 (Amendment) 2022]

“payee” means the person, other than the beneficiary of a life insurance policy, to whom
monies are payable pursuant to paragraphs 6.21(a) to (d) of this Notice;

[MAS Notice 314 (Amendment) 2022]

“personal data” has the same meaning as defined in section 2(1) of the Personal Data
Protection Act 2012;
[MAS Notice 314 (Amendment) 2022]

“reasonable measures” means appropriate measures which are commensurate with the
level of money laundering or terrorism financing risks;

[MAS Notice 314 (Amendment) 2022]

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 “SFA” means the Securities and Futures Act 2001;

[MAS Notice 314 (Amendment) 2022]

“STR” means suspicious transaction report;

“STRO” means the Suspicious Transaction Reporting Office, Commercial Affairs

Department of the Singapore Police Force; and

“TSOFA” means the Terrorism (Suppression of Financing) Act 2002.

[MAS Notice 314 (Amendment) 2022]

2.2 The expressions used in this Notice shall, except where defined in this Notice or where
the context otherwise requires, have the same meanings as in the IA.

3 UNDERLYING PRINCIPLES

3.1 This Notice is based on the following principles, which shall serve as a guide for all direct
life insurers in the conduct of their operations and business activities:

(a) A direct life insurer shall exercise due diligence when dealing with customers,
natural persons appointed to act on the customer’s behalf, connected parties of the
customer and beneficial owners of the customer.

(b) A direct life insurer shall conduct its business in conformity with high ethical
standards, and guard against establishing any business relations or undertaking
any transaction, that is or may be connected with, or facilitates or may facilitate
money laundering or terrorism financing.

(c) A direct life insurer shall, to the fullest extent possible, assist and cooperate with the
relevant law enforcement authorities in Singapore to prevent money laundering and
terrorism financing.

[MAS Notice 314 (Amendment) 2022]

4 ASSESSING RISKS AND APPLYING A RISK-BASED APPROACH

Risk Assessment

4.1 A direct life insurer shall take appropriate steps to identify, assess and understand, its
money laundering and terrorism financing risks in relation to -

(a) its customers;

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 (b) the countries or jurisdictions its customers are from or in;

(c) the countries or jurisdictions the direct life insurer has operations in; and

(d) the products, services, transactions and delivery channels of the direct life insurer.

4.2 The appropriate steps referred to in paragraph 4.1 shall include -

(a) documenting the direct life insurer’s risk assessments;

(b) considering all the relevant risk factors before determining the level of overall risk
and the appropriate type and extent of mitigation to be applied;

(c) keeping the direct life insurer’s risk assessments up-to-date; and

(d) having appropriate mechanisms to provide its risk assessment information to the
Authority.

Risk Mitigation

4.3 A direct life insurer shall -

(a) develop and implement policies, procedures and controls, which are approved by
senior management, to enable the direct life insurer to effectively manage and
mitigate the risks that have been identified by the direct life insurer or notified to it by
the Authority or other relevant authorities in Singapore;

(b) monitor the implementation of those policies, procedures and controls, and enhance
them if necessary;

(c) perform enhanced measures where higher risks are identified, to effectively manage
and mitigate those higher risks; and

(d) ensure that the performance of measures or enhanced measures to effectively

manage and mitigate the identified risks addresses the risk assessment and
guidance from the Authority or other relevant authorities in Singapore.

[MAS Notice 314 (Amendment) 2022]

5 NEW PRODUCTS, PRACTICES AND TECHNOLOGIES

5.1 A direct life insurer shall identify and assess the money laundering and terrorism financing
risks that may arise in relation to -
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 (a) the development of new products and new business practices, including new delivery
mechanisms; and

(b) the use of new or developing technologies for both new and existing products.

[MAS Notice 314 (Amendment) 2022]

5.2 A direct life insurer shall undertake the risk assessments, prior to the launch or use of such
products, practices and technologies (to the extent such use is permitted by this Notice), and
shall take appropriate measures to manage and mitigate the risks.

5.3 A direct life insurer shall, in complying with the requirements of paragraphs 5.1 and 5.2,
pay special attention to any -

(a) new products and new business practices, including new delivery mechanisms; and

(b) new or developing technologies,

that favour anonymity.

6 CUSTOMER DUE DILIGENCE (“CDD”)

Anonymous or Fictitious Person

6.1 No direct life insurer shall deal with any person on an anonymous basis or any person
using a fictitious name.

Where There are Reasonable Grounds for Suspicion prior to the Establishment of Business
Relations

6.2 Prior to a direct life insurer establishing business relations, where the direct life insurer has
any reasonable grounds to suspect that the assets or funds of a customer are proceeds of
drug dealing or criminal conduct as defined in the CDSA, or are property related to the
facilitation or carrying out of any terrorism financing offence as defined in the TSOFA, the
direct life insurer shall -

(a) not establish business relations with the customer; and

(b) file an STR2, and extend a copy to the Authority for information.

2 Please note in particular section 48 of the CDSA on tipping-off.

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When CDD is to be Performed

6.3 A direct life insurer shall perform the measures as required by paragraphs 6, 7 and 8
when -

(a) the direct life insurer establishes business relations with any customer;

(b) there is a suspicion of money laundering or terrorism financing, notwithstanding that

the direct life insurer would not otherwise be required by this Notice to perform the
measures as required by paragraphs 6, 7 and 8; or

(c) the direct life insurer has doubts about the veracity or adequacy of any information
previously obtained.

(I) Identification of Customer

6.4 A direct life insurer shall identify each customer.

6.5 For the purposes of paragraph 6.4, a direct life insurer shall obtain at least the following
information:

(a) full name, including any aliases;

(b) unique identification number (such as an identity card number, birth certificate
number or passport number, or where the customer is not a natural person, the
incorporation number or business registration number);

(c) the customer’s -

(i) residential address; or

(ii) registered or business address, and if different, principal place of business,

as may be appropriate;

(d) date of birth, establishment, incorporation or registration (as may be appropriate);

and

(e) nationality, place of incorporation or place of registration (as may be appropriate).

6.6 Where the customer is a legal person or legal arrangement, the direct life insurer shall,
apart from identifying the customer, also identify the legal form, constitution and powers
that regulate and bind the legal person or legal arrangement.

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6.7 Where the customer is a legal person or legal arrangement, the direct life insurer shall
identify the connected parties of the customer, by obtaining at least the following
information of each connected party:

(a) full name, including any aliases; and

(b) unique identification number (such as an identity card number, birth certificate
number or passport number of the connected party).

6.7A Where the direct life insurer –

(a) has assessed that the money laundering and terrorism financing risks in relation to
the customer are not high; and

(b) is unable to obtain the unique identification number of the connected party after
taking reasonable measures,

the direct life insurer may obtain the date of birth and nationality of the connected party, in
lieu of the unique identification number.
[MAS Notice 314 (Amendment) 2022]

6.7B The direct life insurer shall document the results of the assessment in paragraph 6.7A(a)
and all the measures taken under paragraph 6.7A(b).

[MAS Notice 314 (Amendment) 2022]

(II) Verification of Identity of Customer

6.8 A direct life insurer shall verify the identity of the customer using reliable, independent source
data, documents or information. Where the customer is a legal person or legal arrangement,
a direct life insurer shall verify the legal form, proof of existence, constitution and powers
that regulate and bind the customer, using reliable, independent source data, documents or
information.

(III) Identification and Verification of Identity of Beneficiary

6.9 A direct life insurer shall, as soon as a beneficiary is identified or designated -

(a) for a beneficiary who is identified as a specifically named natural person, legal person
or legal arrangement, obtain the full name, including any aliases, of such beneficiary;
or

(b) for a beneficiary who is designated by characteristics, class or other means, obtain
sufficient information concerning the beneficiary to satisfy itself that it will be able to
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 establish the identity of such beneficiary at the time of payout.

6.10 A direct life insurer shall verify the identity of the beneficiary in accordance with the timing
set out in paragraph 6.38 of the Notice.

(IV) Identification and Verification of Identity of Natural Person Appointed to Act on a Customer’s
Behalf

6.11 Where a customer appoints one or more natural persons to act on the customer’s behalf in
establishing business relations with a direct life insurer or the customer is not a natural
person, the direct life insurer shall -

(a) identify each natural person who acts or is appointed to act on behalf of the customer
by obtaining at least the following information of such natural person:

(i) full name, including any aliases;

(ii) unique identification number (such as an identity card number, birth

certificate number or passport number);

(iii) residential address;

(iv) date of birth;

(v) nationality; and

(b) verify the identity of each natural person using reliable, independent source data,
documents or information.
[MAS Notice 314 (Amendment) 2022]

6.12 A direct life insurer shall verify the due authority of each natural person appointed to act on
behalf of the customer by:-

(a) obtaining the appropriate documentary evidence authorising the appointment of such
natural person by the customer to act on the customer’s behalf; and

(b) verifying that such natural person is the person authorised to act on the customer’s
behalf, through methods which include obtaining the person’s specimen signature or
electronic means of verification.

[MAS Notice 314 (Amendment) 2022]

6.12A Where the direct life insurer –

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 (a) has assessed that the money laundering and terrorism financing risks of the
customer are not high; and

(b) is unable to obtain the residential address of the natural person who acts or is
appointed to act on behalf of the customer after taking reasonable measures,

the direct life insurer may obtain the business address of this natural person, in lieu of the
residential address.

[MAS Notice 314 (Amendment) 2022]

6.12B Where the direct life insurer has obtained the business address of the natural person referred
to in paragraph 6.12A, the direct life insurer shall take reasonable measures to verify the
business address using reliable, independent source data, documents or information.

[MAS Notice 314 (Amendment) 2022]

6.12C The direct life insurer shall document the results of the assessment in paragraph 6.12A(a)
and all the measures taken under paragraph 6.12A(b).

[MAS Notice 314 (Amendment) 2022]

6.13 Where the customer is a Singapore Government entity, the direct life insurer shall only be
required to obtain such information as may be required to confirm that the customer is a
Singapore Government entity as asserted.

(V) Identification and Verification of Identity of Beneficial Owner

6.14 For the purposes of paragraphs 6.15 to 6.20 -

(a) a reference to a beneficiary means a beneficiary that is -

(i) a legal person or legal arrangement; and

(ii) assessed by the direct life insurer to present a higher risk for money
laundering or terrorism financing; and

(b) a reference to a beneficial owner of a beneficiary means the natural person who
ultimately owns or controls the beneficiary and includes any person who exercises
ultimate effective control over the beneficiary.

6.15 Subject to paragraph 6.19, a direct life insurer shall inquire if there exists any beneficial
owner of a customer or beneficial owner of a beneficiary.

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6.16 Where there is one or more beneficial owners of a customer or one or more beneficial owners
of a beneficiary, the direct life insurer shall identify the beneficial owners and take reasonable
measures to verify the identities of the beneficial owners using the relevant information or
data obtained from reliable, independent sources. The direct life insurer shall -

(a) for customers or beneficiaries that are legal persons -

(i) identify the natural persons (whether acting alone or together) who ultimately
own the legal person;

(ii) to the extent that there is doubt under subparagraph (i) as to whether the
natural persons who ultimately own the legal person are the beneficial
owners or where no natural persons ultimately own the legal person, identify
the natural persons (if any) who ultimately control the legal person or have
ultimate effective control of the legal person; and

(iii) where no natural persons are identified under subparagraphs (i) or (ii),
identify the natural persons having executive authority in the legal person, or
in equivalent or similar positions;

(b) for customers or beneficiaries that are legal arrangements -

(i) for trusts, identify the settlors, the trustees, the protector (if any), the
beneficiaries of the trust (including every beneficiary that falls within a
designated characteristic or class)3, and any natural person exercising
ultimate ownership, ultimate control or ultimate effective control over the trust
(including through a chain of control or ownership); and

(ii) for other types of legal arrangements, identify persons in equivalent or similar
positions, as those described under subparagraph (i).

[MAS Notice 314 (Amendment) 2022]

6.17 A direct life insurer shall identify the beneficial owners of a beneficiary at the time of payout.

6.18 Where the customer or beneficiary is not a natural person, the direct life insurer shall
understand the nature of the customer’s or the beneficiary’s business and its ownership and
control structure.

3 In relation to a beneficiary of a trust designated by characteristics or by class, the direct life insurer shall obtain sufficient
information about the beneficiary to satisfy itself that it will be able to establish the identity of the beneficiary –
(a) before making a distribution to that beneficiary; or
(b) when that beneficiary intends to exercise vested rights.

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6.19 A direct life insurer shall not be required to inquire if there exists any beneficial owner in
relation to, a customer or a beneficiary that is -

(a) Deleted with effect from 30 November 2015;

(b) Deleted with effect from 30 November 2015;

(c) an entity listed and traded on the Singapore Exchange;

(d) an entity listed on a stock exchange outside of Singapore that is subject to -

(i) regulatory disclosure requirements; and

(ii) requirements relating to adequate transparency in respect of its beneficial

owners (imposed through stock exchange rules, law or other enforceable
means);

(e) a financial institution set out in Appendix 1;

(f) a financial institution incorporated or established outside Singapore that is subject to

and supervised for compliance with AML/CFT requirements consistent with
standards set by the FATF; or

(g) an investment vehicle where the managers are financial institutions 4 -

(i) set out in Appendix 1; or

(ii) incorporated or established outside Singapore but are subject to and

supervised for compliance with AML/CFT requirements consistent with
standards set by the FATF,

unless the direct life insurer has doubts about the veracity of the CDD information, or
suspects that the customer, beneficiary, business relations with, or transaction undertaken
in the course of business relations for, the customer, may be connected with money
laundering or terrorism financing.

[MAS Notice 314 (Amendment) 2015]

[MAS Notice 314 (Amendment) 2022]

4For the avoidance of doubt, the direct life insurer shall be required to inquire if there exists any beneficial owners in relation to a
customer that is an investment vehicle to which it provides the regulated activity of fund management as the primary manager,
except where the interests in the investment vehicle are distributed by a financial institution as described in paragraphs 6.19(e) or
6.19(f).
[MAS Notice 314 (Amendment) 2022]
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6.20 For the purposes of paragraphs 6.19(f) and 6.19(g)(ii), a direct life insurer shall document
the basis for its determination that the requirements in those paragraphs have been duly
met.

(VI) Identification and Verification of Identity of Payee

6.21 Where the payee is not the customer, a direct life insurer shall identify the payee and verify
the payee’s identity at the time of making any of the following types of payment:

(a) payment of the sum assured (or part thereof) upon the occurrence of the risk insured
against in accordance with a life policy;

(b) payment of the surrender value of a life policy;

(c) refund of premium upon the avoidance, cancellation or termination of a life policy; or

(d) any other payment made in relation to any life policy.

[MAS Notice 314 (Amendment) 2022]

(VII) Information on the Purpose and Intended Nature of Business Relations

6.22 A direct life insurer shall, when processing the application to establish business relations,
understand and as appropriate, obtain from the customer information as to the purpose and
intended nature of business relations.

(VIII) Ongoing Monitoring

6.23 A direct life insurer shall monitor on an ongoing basis, its business relations with customers.

6.24 A direct life insurer shall, during the course of business relations with a customer, observe
the conduct of the customer’s life policy and scrutinise transactions undertaken in the course
of business relations, to ensure that the transactions are consistent with the direct life
insurer’s knowledge of the customer, its business and risk profile and where appropriate, the
source of funds.

6.25 A direct life insurer shall pay special attention to all complex, unusually large or unusual
patterns of transactions, undertaken in the course of business relations, that have no
apparent or visible economic or lawful purpose.

6.26 For the purposes of ongoing monitoring, a direct life insurer shall put in place and implement
adequate systems and processes, commensurate with the size and complexity of the direct
life insurer, to -

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 (a) monitor its business relations with customers; and

(b) detect and report suspicious, complex, unusually large or unusual patterns of
transactions.

6.27 A direct life insurer shall, to the extent possible, inquire into the background and purpose of
the transactions in paragraph 6.25 and document its findings with a view to making this
information available to the relevant authorities should the need arise.

6.28 A direct life insurer shall ensure that the CDD data, documents and information obtained in
respect of customers, natural persons appointed to act on behalf of the customers,
connected parties of the customers and beneficial owners of the customers, are relevant and
kept up-to-date by undertaking reviews of existing CDD data, documents and information,
particularly for higher risk categories of customers.

6.29 Where there are any reasonable grounds for suspicion that existing business relations with
a customer are connected with money laundering or terrorism financing, and where the direct
life insurer considers it appropriate to retain the customer -

(a) the direct life insurer shall substantiate and document the reasons for retaining the
customer; and

(b) the customer’s business relations with the direct life insurer shall be subject to
commensurate risk mitigation measures, including enhanced ongoing monitoring.

6.30 Where the direct life insurer assesses the customer or the business relations with the
customer referred to in paragraph 6.29 to be of higher risk, the direct life insurer shall perform
enhanced CDD measures, which shall include obtaining the approval of the direct life
insurer’s senior management to retain the customer.

CDD Measures for Non-Face-to-Face Business Relations

6.31 A direct life insurer shall develop policies and procedures to address any specific risks
associated with non-face-to-face business relations with a customer or transactions
undertaken in the course of non-face-to-face business relations for a customer.

6.32 A direct life insurer shall implement the policies and procedures referred to in paragraph
6.31 when establishing business relations with a customer and when conducting ongoing
due diligence.

6.33 Where there is no face-to-face contact, the direct life insurer shall perform CDD measures
that are at least as robust as those that would be required to be performed if there was face-
to-face contact.

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 [MAS Notice 314 (Amendment) 2022]

Reliance by Acquiring Direct Life Insurer on Measures Already Performed

6.34 When a direct life insurer (“acquiring direct life insurer”) acquires, either in whole or in part,
the business of another financial institution (whether in Singapore or elsewhere), the
acquiring direct life insurer shall perform the measures as required by paragraphs 6, 7 and
8, on the customers acquired with the business at the time of acquisition except where the
acquiring direct life insurer has -

(a) acquired at the same time all corresponding customer records (including CDD
information) and has no doubt or concerns about the veracity or adequacy of the
information so acquired; and

(b) conducted due diligence enquiries that have not raised any doubt on the part of the
acquiring direct life insurer as to the adequacy of AML/CFT measures previously
adopted in relation to the business or part thereof now acquired by the acquiring
direct life insurer, and document such enquiries.

Timing for Verification

6.35 Subject to paragraphs 6.36 and 6.37, a direct life insurer shall complete verification of the
identity of a customer as required by paragraph 6.8, natural persons appointed to act on
behalf of the customer as required by paragraph 6.11(b) and beneficial owners of the
customer as required by paragraph 6.16 before the direct life insurer establishes business
relations with the customer.

6.36 A direct life insurer may establish business relations with a customer before completing the
verification of the identity of the customer as required by paragraph 6.8, natural persons
appointed to act on behalf of the customer as required by paragraph 6.11(b) and beneficial
owners of the customer as required by paragraph 6.16 if -

(a) the deferral of completion of the verification is essential in order not to interrupt the
normal conduct of business operations; and

(b) the risks of money laundering and terrorism financing can be effectively managed by
the direct life insurer.

6.37 Where the direct life insurer establishes business relations with a customer before verifying
the identity of the customer as required by paragraph 6.8, natural persons appointed to act
on behalf of the customer as required by paragraph 6.11(b), and beneficial owners of the
customer as required by paragraph 6.16, the direct life insurer shall -

(a) develop and implement internal risk management policies and procedures
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 concerning the conditions under which such business relations may be established
prior to verification; and

(b) complete such verification as soon as is reasonably practicable.

6.38 A direct life insurer shall verify the identity of -

(a) beneficiaries; and

(b) the beneficial owners of beneficiaries referred to in paragraph 6.14,

at the time of payout.

Where Measures are not Completed

6.39 Where the direct life insurer is unable to complete the measures as required by paragraphs
6, 7 and 8, it shall not commence or continue business relations with any customer, including
making any payment to a payee or beneficiary. The direct life insurer shall consider if the
circumstances are suspicious so as to warrant the filing of an STR.

6.40 For the purposes of paragraph 6.39, completion of the measures means the situation where
the direct life insurer has obtained, screened and verified (including by delayed verification
as allowed under paragraphs 6.36 and 6.37) all necessary CDD information required under
paragraphs 6, 7 and 8, and where the direct life insurer has received satisfactory responses
to all inquiries in relation to such necessary CDD information.

[MAS Notice 314 (Amendment) 2022]

Jointly-Owned Policy

6.41 In the case of a jointly-owned policy, a direct life insurer shall perform CDD measures on all
of the policy owners as if each of them were individual customers of the direct life insurer.

Existing Customers

6.42 A direct life insurer shall perform the measures as required by paragraphs 6, 7 and 8 in
relation to its existing customers, based on its own assessment of materiality and risk, taking
into account any previous measures applied, the time when the measures were last applied
to such existing customers and the adequacy of data, documents or information obtained.

Screening

6.43 A direct life insurer shall screen a customer, natural persons appointed to act on behalf of
the customer, connected parties of the customer and beneficial owners of the customer
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 against relevant money laundering and terrorism financing information sources, as well as
lists and information provided by the Authority or other relevant authorities in Singapore for
the purposes of determining if there are any money laundering or terrorism financing risks in
relation to the customer.

6.44 A direct life insurer shall screen the persons referred to in paragraph 6.43 -

(a) when, or as soon as reasonably practicable after, the direct life insurer establishes
business relations with a customer;

(b) on a periodic basis after the direct life insurer establishes business relations with the
customer; and

(c) when there are any changes or updates to -

(i) the lists and information provided by the Authority or other relevant authorities
in Singapore to the direct life insurer; or

(ii) the natural persons appointed to act on behalf of a customer, connected

parties of a customer or beneficial owners of a customer.

6.45 A direct life insurer shall screen, at the time of payout, each -

(a) payee;

(b) beneficiary; and

(c) beneficial owner of a beneficiary referred to in paragraph 6.14,

against relevant money laundering and terrorism financing information sources, as well as
lists and information provided by the Authority or other relevant authorities in Singapore for
the purposes of determining if there are any money laundering or terrorism financing risks in
relation to any such persons.

6.46 The results of screening and assessment by the direct life insurer shall be documented.

7 SIMPLIFIED CUSTOMER DUE DILIGENCE

7.1 Subject to paragraph 7.4, a direct life insurer may perform simplified CDD measures in
relation to a customer, any beneficiary, any natural person appointed to act on behalf of the
customer, any beneficial owner of the customer (other than any beneficial owner that the
direct life insurer is exempted from making inquiries about under paragraph 6.19) and any
beneficial owner of a beneficiary referred to in paragraph 6.14 if it is satisfied that the risks
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 of money laundering and terrorism financing are low.

[MAS Notice 314 (Amendment) 2015]

7.2 The assessment of low risks shall be supported by an adequate analysis of risks by the
direct life insurer.
7.3 The simplified CDD measures shall be commensurate with the level of risk, based on the
risk factors identified by the direct life insurer.

7.4 A direct life insurer shall not perform simplified CDD measures -

(a) where a customer or any beneficial owner of the customer is from or in a country or
jurisdiction in relation to which the FATF has called for countermeasures;

(b) where a customer or any beneficial owner of the customer is from or in a country or
jurisdiction known to have inadequate AML/CFT measures, as determined by the
direct life insurer for itself, or notified to direct life insurers generally by the Authority
or other foreign regulatory authorities; or

(c) where the direct life insurer suspects that money laundering or terrorism financing is
involved.
[MAS Notice 314 (Amendment) 2022]

7.5 Subject to paragraphs 7.2, 7.3 and 7.4, a direct life insurer may perform simplified CDD
measures in relation to a customer that is a financial institution set out in Appendix 2.

7.6 Where the direct life insurer performs simplified CDD measures in relation to a customer,
any beneficiary, any natural person appointed to act on behalf of the customer, any beneficial
owner of the customer and any beneficial owner of a beneficiary referred to in paragraph
6.14, it shall document -

(a) the details of its risk assessment; and

(b) the nature of the simplified CDD measures.

7.7 For avoidance of doubt, the term “CDD measures” in paragraph 7 means the measures
required by paragraph 6.

[MAS Notice 314 (Amendment) 2015]

8 ENHANCED CUSTOMER DUE DILIGENCE

Politically Exposed Persons

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8.1 For the purposes of paragraph 8 -

“close associate” means a natural person who is closely connected to a politically exposed
person, either socially or professionally;

“domestic politically exposed person” means a natural person who is or has been entrusted
domestically with prominent public functions;

“family member” means a parent, step-parent, child, step-child, adopted child, spouse,
sibling, step-sibling and adopted sibling of the politically exposed person;

“foreign politically exposed person” means a natural person who is or has been entrusted
with prominent public functions in a foreign country or jurisdiction;

[MAS Notice 314 (Amendment) 2022]

“international organisation” means an entity established by formal political agreements

between member countries or jurisdictions that have the status of international treaties,
whose existence is recognised by law in member countries or jurisdictions and which is not
treated as a resident institutional unit of the country or jurisdiction in which it is located;

[MAS Notice 314 (Amendment) 2022]

“international organisation politically exposed person” means a natural person who is or has
been entrusted with prominent public functions in an international organisation;

“politically exposed person” means a domestic politically exposed person, foreign politically
exposed person or international organisation politically exposed person; and

“prominent public functions” includes the roles held by a head of state, a head of government,
government ministers, senior civil or public servants, senior judicial or military officials, senior
executives of state owned corporations, senior political party officials, members of the
legislature and senior management of international organisations.

8.2 A direct life insurer shall implement appropriate internal risk management systems, policies,
procedures and controls to determine if a customer, any beneficiary, any natural person
appointed to act on behalf of the customer, any connected party of the customer, any
beneficial owner of the customer or any beneficial owner of a beneficiary referred to in
paragraph 6.14 is a politically exposed person, or a family member or close associate of a
politically exposed person.

8.3 A direct life insurer shall, in addition to performing CDD measures (specified in paragraph
6), perform at least the following enhanced CDD measures where a customer, any
19
 beneficiary, any beneficial owner of the customer or any beneficial owner of a beneficiary
referred to in paragraph 6.14 is determined by the direct life insurer to be a politically exposed
person, or a family member or close associate of a politically exposed person under
paragraph 8.2:

(a) obtain approval from the direct life insurer’s senior management to establish or
continue business relations with the customer, including making any payment to a
beneficiary;

(b) establish, by appropriate and reasonable means, the source of wealth and source of
funds of the customer and any beneficial owner of the customer; and

(c) conduct, during the course of business relations with the customer, enhanced
monitoring of business relations with the customer. In particular, the direct life insurer
shall increase the degree and nature of monitoring of the business relations with, and
transactions undertaken in the course of business relations for, the customer, in order
to determine whether they appear unusual or suspicious.

8.4 A direct life insurer may adopt a risk-based approach in determining whether to perform
enhanced CDD measures or the extent of enhanced CDD measures to be performed for -

(a) domestic politically exposed persons, their family members and close associates;

(b) international organisation politically exposed persons, their family members and
close associates; or

(c) politically exposed persons who have stepped down from their prominent public
functions, taking into consideration the level of influence such persons may continue
to exercise after stepping down from their prominent public functions, their family
members and close associates,

except in cases where their business relations or transactions with the direct life insurer
present a higher risk for money laundering or terrorism financing.

Other Higher Risk Categories

8.5 A direct life insurer shall implement appropriate internal risk management systems, policies,
procedures and controls to determine if business relations with, or transactions undertaken
in the course of business relations for, any customer present a higher risk for money
laundering or terrorism financing.

8.6 For the purposes of paragraph 8.5, circumstances where a customer presents or may
present a higher risk for money laundering or terrorism financing include but are not limited
to the following:
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 (a) where a customer, any beneficiary, any beneficial owner of the customer or any
beneficial owner of a beneficiary referred to in paragraph 6.14 is from or in a country
or jurisdiction in relation to which the FATF has called for countermeasures, the direct
life insurer shall treat any business relations with, or transactions undertaken in the
course of business relations for, any such customer as presenting a higher risk for
money laundering or terrorism financing;

(b) where a customer, any beneficiary, any beneficial owner of the customer or any
beneficial owner of a beneficiary referred to in paragraph 6.14 is from or in a country
or jurisdiction known to have inadequate AML/CFT measures, as determined by the
direct life insurer for itself, or notified to direct life insurers generally by the Authority
or other foreign regulatory authorities, the direct life insurer shall assess whether any
such customer presents a higher risk for money laundering or terrorism financing;
and

(c) where a customer is a legal person for which the direct life insurer is not able to
establish if it has any –

(i) ongoing, apparent or visible operation or business activity;

(ii) economic or business purpose for its corporate structure or arrangement; or

(iii) substantive financial activity in its interactions with the direct life insurer,

the direct life insurer shall assess whether any such customer presents a higher risk
for money laundering or terrorism financing.

[MAS Notice 314 (Amendment) 2015]

[MAS Notice 314 (Amendment) 2022]

8.7 A direct life insurer shall perform the appropriate enhanced CDD measures in paragraph 8.3
for business relations with, or transactions undertaken in the course of business relations
for, any customer -

(a) who the direct life insurer determines under paragraph 8.5; or

(b) the Authority or other relevant authorities in Singapore notify to the direct life insurer,

as presenting a higher risk for money laundering or terrorism financing.

8.7A For avoidance of doubt, in determining whether the business relations with, or transactions
undertaken in the course of business relations for, any customer present a higher risk for
money laundering or terrorism financing under paragraphs 8.5 and 8.7, the direct life insurer
21
 shall include each beneficiary as a relevant risk factor.

[MAS Notice 314 (Amendment) 2015]

8.8 A direct life insurer shall, in taking enhanced CDD measures to manage and mitigate any
higher risks that have been identified by the direct life insurer, or notified to it by the Authority
or other relevant authorities in Singapore, ensure that the enhanced CDD measures take
into account the requirements of any laws, regulations or directions administered by the
Authority, including but not limited to the regulations or directions issued by the Authority
under section 27A of the MAS Act.

[MAS Notice 314 (Amendment) 2022]

9 RELIANCE ON THIRD PARTIES

9.1 For the purposes of paragraph 9, “third party” means -

(a) a financial institution set out in Appendix 2;

(b) a financial institution which is subject to and supervised by a foreign authority for
compliance with AML/CFT requirements consistent with standards set by the FATF
(other than a holder of a payment services licence under the Payment Services Act
2019, or equivalent licences);

(c) in relation to a direct life insurer incorporated in Singapore, its branches, subsidiaries,
parent entity, the branches and subsidiaries of the parent entity, and other related
corporations; or

(d) in relation to a direct life insurer incorporated outside Singapore, its head office, its
parent entity, the branches and subsidiaries of the head office, the branches and
subsidiaries of the parent entity, and other related corporations.

[MAS Notice 314 (Amendment) 2022]

9.2 Subject to paragraph 9.3, a direct life insurer may rely on a third party to perform the
measures as required by paragraphs 6, 7 and 8 if the following requirements are met:

(a) the direct life insurer is satisfied that the third party it intends to rely upon is subject
to and supervised for compliance with AML/CFT requirements consistent with
standards set by the FATF, and has adequate AML/CFT measures in place to comply
with those requirements;

(b) the direct life insurer takes appropriate steps to identify, assess and understand the
money laundering and terrorism financing risks particular to the countries or
22
 jurisdictions that the third party operates in;

(c) the third party is not one which direct life insurers have been specifically precluded
by the Authority from relying upon; and

(d) the third party is able and willing to provide, without delay, upon the direct life
insurer’s request, any data, documents or information obtained by the third party with
respect to the measures applied on the direct life insurer’s customer, which the direct
life insurer would be required or would want to obtain.

9.3 No direct life insurer shall rely on a third party to conduct ongoing monitoring of business
relations with customers.

9.4 Where a direct life insurer relies on a third party to perform the measures as required by
paragraphs 6, 7 and 8, it shall -

(a) document the basis for its satisfaction that the requirements in paragraphs 9.2(a) and
(b) have been met, except where the third party is a financial institution set out in
Appendix 2; and

(b) immediately obtain from the third party the CDD information which the third party had
obtained.

9.5 For the avoidance of doubt, notwithstanding the reliance upon a third party, the direct life
insurer shall remain responsible for its AML/CFT obligations in this Notice.

10 RECORD KEEPING

10.1 A direct life insurer shall, in relation to all data, documents and information that the direct life
insurer is required to obtain or produce to meet the requirements under this Notice, prepare,
maintain and retain records of such data, documents and information.

10.2 A direct life insurer shall perform the measures as required by paragraph 10.1 such that-

(a) all requirements imposed by law (including this Notice) are met;

(b) any individual transaction undertaken by the direct life insurer in the course of
business relations can be reconstructed (including the amount and type of currency
involved) so as to provide, if necessary, evidence for prosecution of criminal activity;

(c) the Authority or other relevant authorities in Singapore and the internal and external
auditors of the direct life insurer are able to review the direct life insurer’s business
relations, transactions undertaken in the course of business relations, records and
23
 CDD information and assess the level of compliance with this Notice; and

(d) the direct life insurer can satisfy, within a reasonable time or any more specific time
period imposed by law or by the requesting authority, any enquiry or order from the
relevant authorities in Singapore for information.

10.3 Subject to paragraph 10.5 and any other requirements imposed by law, a direct life insurer
shall, for the purposes of record retention under paragraphs 10.1 and 10.2, and when setting
its record retention policies, comply with the following record retention periods:

(a) for CDD information relating to the business relations and transactions undertaken
in the course of business relations, as well as policy files, business correspondence
and results of any analysis undertaken, a period of at least 5 years following the
termination of such business relations; and

(b) for data, documents and information relating to a transaction undertaken in the
course of business relations, including any information needed to explain and
reconstruct the transaction, a period of at least 5 years following the completion of
the transaction.

10.4 A direct life insurer may retain data, documents and information as originals or copies, in
paper or electronic form or on microfilm, provided that they are admissible as evidence in a
Singapore court of law.

10.5 A direct life insurer shall retain records of data, documents and information on all its business
relations with, or transactions undertaken in the course of business relations for, a customer
pertaining to a matter which is under investigation or which has been the subject of an STR,
in accordance with any request or order from STRO or other relevant authorities in
Singapore.

11 PERSONAL DATA

11.1 For the purposes of paragraph 11, “individual” means a natural person, whether living or
deceased.

11.2 Subject to paragraph 11.3 and for the purposes of complying with this Notice, a direct life
insurer shall not be required to provide an individual customer, an individual beneficiary, an
individual appointed to act on behalf of a customer, an individual connected party of a
customer, an individual beneficial owner of a customer, an individual beneficial owner of a
beneficiary referred to in paragraph 6.14 or an individual payee, with -

(a) any access to personal data about the individual that is in the possession or under
the control of the direct life insurer;
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 (b) any information about the ways in which the personal data of the individual under
subparagraph (a) has been or may have been used or disclosed by the direct life
insurer; and

(c) any right to correct an error or omission of the personal data about the individual that
is in the possession or under the control of the direct life insurer.

[MAS Notice 314 (Amendment) 2022]

11.3 A direct life insurer shall, as soon as reasonably practicable, upon the request of an individual
customer, an individual appointed to act on behalf of a customer, an individual connected
party of a customer, an individual beneficial owner of a customer or an individual payee,
provide the requesting individual with the right to -

(a) access the following types of personal data of that individual, that is in the possession
or under the control of the direct life insurer:

(i) the individual’s full name, including any alias;

(ii) the individual’s unique identification number (such as an identity card

number, birth certificate number or passport number);

(iii) the individual’s residential address;

(iv) the individual’s date of birth;

(v) the individual’s nationality;

(vi) subject to sections 21(2) and (3) read with the Fifth Schedule to the Personal
Data Protection Act 2012, any other personal data of the respective individual
provided by that individual to the direct life insurer; and

(b) subject to section 22(7) read with the Sixth Schedule to the Personal Data Protection
Act 2012, correct an error or omission in relation to the types of personal data set out
in subparagraphs (a)(i) to (vi), provided the direct life insurer is satisfied that there
are reasonable grounds for such request.
[MAS Notice 314 (Amendment) 2022]

11.4 For the purposes of complying with this Notice, a direct life insurer may, whether directly or
through a third party, collect, use and disclose personal data of an individual customer, an
individual beneficiary, an individual appointed to act on behalf of a customer, an individual
connected party of a customer, an individual beneficial owner of a customer, an individual
beneficial owner of a beneficiary referred to in paragraph 6.14 or an individual payee, without
25
 the respective individual’s consent.

12 SUSPICIOUS TRANSACTIONS REPORTING

12.1 A direct life insurer shall keep in mind the provisions in the CDSA 5 and in the TSOFA that
provide for the reporting to the authorities of transactions suspected of being connected with
money laundering or terrorism financing and implement appropriate internal policies,
procedures and controls for meeting its obligations under the law, including the following:

(a) establish a single reference point within the organisation to whom all officers,
employees and agents are instructed to promptly refer all transactions suspected of
being connected with money laundering or terrorism financing, for possible referral
to STRO via STRs; and

(b) keep records of all transactions referred to STRO, together with all internal findings
and analysis done in relation to them.

12.2 A direct life insurer shall promptly submit reports on suspicious transactions (including
attempted transactions), regardless of the amount of the transaction, to STRO, and extend
a copy to the Authority for information.

12.3 A direct life insurer shall consider if the circumstances are suspicious so as to warrant the
filing of an STR and document the basis for its determination, including where -

(a) the direct life insurer is for any reason unable to complete the measures as required
by paragraphs 6, 7 and 8; or

(b) the customer is reluctant, unable or unwilling to provide any information requested
by the direct life insurer, or decides to withdraw a pending application to establish
business relations or a pending transaction, or to terminate existing business
relations.
[MAS Notice 314 (Amendment) 2022]

12.4 Where a direct life insurer forms a suspicion of money laundering or terrorism financing, and
reasonably believes that performing any of the measures as required by paragraphs 6, 7 or
8 will tip-off a customer, a beneficiary, a natural person appointed to act on behalf of the
customer, a connected party of the customer, a beneficial owner of the customer, a beneficial
owner of a beneficiary referred to in paragraph 6.14 or a payee, the direct life insurer may
stop performing those measures. The direct life insurer shall document the basis for its
assessment and file an STR.

5 Please note in particular section 48 of the CDSA on tipping-off.

26
12.5 For avoidance of doubt, where any beneficiary, or beneficial owner of a beneficiary referred
to in paragraph 6.14, is a politically exposed person, or a family member or close associate
of a politically exposed person and where higher risks are identified, the direct life insurer
shall consider filing an STR.

[MAS Notice 314 (Amendment) 2015]

12.6 For the purposes of paragraph 12.5, the terms “close associate”, “family member” and
“politically exposed person” have the same meanings as defined in paragraph 8.1.

[MAS Notice 314 (Amendment) 2015]

13 INTERNAL POLICIES, COMPLIANCE, AUDIT AND TRAINING

13.1 A direct life insurer shall develop and implement adequate internal policies, procedures and
controls, taking into consideration its money laundering and terrorism financing risks and the
size of its business, to help prevent money laundering and terrorism financing and
communicate these to its employees and agents.

13.2 The policies, procedures and controls shall meet all the requirements of this Notice.

[MAS Notice 314 (Amendment) 2022]

Group Policy

13.3 For the purposes of paragraphs 13.4 to 13.9, a reference to “direct life insurer” means a
direct life insurer incorporated in Singapore.

[MAS Notice 314 (Amendment) 2022]

13.4 A direct life insurer shall develop a group policy on AML/CFT to meet all the requirements of
this Notice and extend this to all of its branches and subsidiaries in its financial group.

[MAS Notice 314 (Amendment) 2022]

13.5 Where a direct life insurer has a branch or subsidiary in a host country or jurisdiction -

(a) in relation to which the FATF has called for countermeasures; or

(b) known to have inadequate AML/CFT measures, as determined by the direct life
insurer for itself, or notified to direct life insurers generally by the Authority or other
foreign regulatory authorities,

27
 the direct life insurer shall ensure that its group policy on AML/CFT is strictly observed by
the management of that branch or subsidiary.

[MAS Notice 314 (Amendment) 2022]

13.6 Subject to the direct life insurer putting in place adequate safeguards to protect the
confidentiality and use of any information that is shared, the direct life insurer shall develop
and implement group policies and procedures for its branches and subsidiaries within the
financial group, to share information required for the purposes of CDD and for money
laundering and terrorism financing risk management, to the extent permitted by the law of
the countries or jurisdictions that its branches and subsidiaries are in.

13.7 Such policies and procedures shall include the provision, to the direct life insurer’s group-
level compliance, audit, and AML/CFT functions, of customer, account, and transaction
information from its branches and subsidiaries within the financial group, when necessary
for money laundering and terrorism financing risk management purposes.

13.7A For the purposes of paragraph 13.7, the information to be shared within the direct life
insurer’s financial group shall include any information and analysis of transactions or
activities that appear unusual. 6
[MAS Notice 314 (Amendment) 2022]

13.8 Where the AML/CFT requirements in the host country or jurisdiction differ from those in
Singapore, the direct life insurer shall require that the overseas branch or subsidiary apply
the higher of the two standards, to the extent that the law of the host country or jurisdiction
so permits.

13.9 Where the law of the host country or jurisdiction conflicts with Singapore law such that the
overseas branch or subsidiary is unable to fully observe the higher standard, the direct life
insurer shall apply additional appropriate measures to manage the money laundering and
terrorism financing risks, report this to the Authority and comply with such further directions
as may be given by the Authority.

13.9A In the case of a Singapore branch of a direct life insurer incorporated outside Singapore,
subject to the Singapore branch putting in place adequate safeguards to protect the
confidentiality and use of any information that is shared, the Singapore branch shall share
customer, account and transaction information within the direct life insurer’s financial group
when necessary for money laundering and terrorism financing risk management purposes.
Such information to be shared within the direct life insurer’s financial group shall include any

6Subject to section 48 of the CDSA on tipping-off, information shared may include an STR, the underlying information of the
STR, or the fact that STR was filed.
[MAS Notice 314 (Amendment) 2022]
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 information and analysis of transactions or activities that appear unusual.7

[MAS Notice 314 (Amendment) 2022]

Compliance

13.10 A direct life insurer shall develop appropriate compliance management arrangements,
including at least, the appointment of an AML/CFT compliance officer at the management
level.

13.11 A direct life insurer shall ensure that the AML/CFT compliance officer, as well as any other
persons appointed to assist the AML/CFT compliance officer, is suitably qualified, and has
adequate resources and timely access to all customer records and other relevant information
which the AML/CFT compliance officer requires to discharge the AML/CFT compliance
officer’s functions.

[MAS Notice 314 (Amendment) 2022]

Audit

13.12 A direct life insurer shall maintain an audit function that is adequately resourced and
independent, and that is able to regularly assess the effectiveness of the direct life insurer’s
internal policies, procedures and controls, and its compliance with regulatory requirements.

Officer, Employee and Agent Hiring

13.13 A direct life insurer shall have in place screening procedures to ensure high standards when
hiring employees and appointing officers and agents.

Training

13.14 A direct life insurer shall take all appropriate steps to ensure that its officers, employees and
agents (whether in Singapore or elsewhere) are regularly and appropriately trained on –

(a) AML/CFT laws and regulations, and in particular, CDD measures, and detecting and
reporting of suspicious transactions;

(b) prevailing techniques, methods and trends in money laundering and terrorism
financing; and

7Subject to section 48 of the CDSA on tipping-off, information shared may include an STR, the underlying information of the
STR, or the fact that an STR was filed.
[MAS Notice 314 (Amendment) 2022]
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 (c) the direct life insurer’s internal AML/CFT policies, procedures and controls, and the
roles and responsibilities of officers, employees and agents in combating money
laundering and terrorism financing.

[MAS Notice 314 (Amendment) 2022]

Endnotes on History of Amendments

1. MAS Notice 314 dated 2 July 2007.
(a) MAS Notice 314 (Amendment) 2009 dated 3 July 2009 with effect from 2
December 2009.
(b) MAS Notice 314 (Amendment) 2013 with effect from 23 January 2013.
(c) MAS Notice 314 (Amendment) 2014 with effect from 1 July 2014.
2. MAS Notice 314 dated 2 July 2007 cancelled with effect from 24 May 2015.
3. MAS Notice 314 dated 24 April 2015 with effect from 24 May 2015.
(a) MAS Notice 314 (Amendment) 2015 with effect from 30 November 2015
(b) MAS Notice 314 (Amendment) 2021 with effect from 1 July 2021.
(c) MAS Notice 314 (Amendment) 2022 with effect from 1 March 2022.

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Appendix 1

1. Financial institutions that are licensed, approved, registered (including a fund management
company registered under paragraph 5(1)(i) of the Second Schedule to the Securities and
Futures (Licensing and Conduct of Business) Regulations (Rg. 10)) or regulated by the Authority
but does not include a person (other than a person referred to in paragraphs 2 and 3) who is
exempted from licensing, approval or regulation by the Authority under any Act administered by
the Authority, including a private trust company exempted from licensing under section 15 of the
Trust Companies Act 2005 read with regulation 4 of the Trust Companies (Exemption)
Regulations (Rg. 1).

[MAS Notice 314 (Amendment) 2021]

[MAS Notice 314 (Amendment) 2022]

2. Persons exempted under section 23(1)(f) of the Financial Advisers Act 2001 read with regulation
27(1)(d) of the Financial Advisers Regulations (Rg. 2).

[MAS Notice 314 (Amendment) 2022]

3. Persons exempted under section 99(1)(h) of the SFA read with paragraph 7(1)(b) of the Second
Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations.

[MAS Notice 314 (Amendment) 2022]

Note: For the avoidance of doubt, the financial institutions set out in Appendix 2 fall within Appendix
1.

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Appendix 2

1. Banks in Singapore licensed under the Banking Act 1970.

[MAS Notice 314 (Amendment) 2021]

[MAS Notice 314 (Amendment) 2022]

2. Merchant banks in Singapore licensed under the Banking Act 1970.

[MAS Notice 314 (Amendment) 2021]

[MAS Notice 314 (Amendment) 2022]

3. Finance companies licensed under section 6 of the Finance Companies Act 1967.

[MAS Notice 314 (Amendment) 2022]

4. Financial advisers licensed under section 6 of the Financial Advisers Act 2001 except those
which only provide advice by issuing or promulgating research analyses or research reports,
whether in electronic, print or other form, concerning any investment product.

[MAS Notice 314 (Amendment) 2022]

5. Holders of a capital markets services licence under section 82 of the SFA.

[MAS Notice 314 (Amendment) 2022]

6. Fund management companies registered under paragraph 5(1)(i) of the Second Schedule to the
Securities and Futures (Licensing and Conduct of Business) Regulations (Rg. 10).

7. Persons exempted under section 23(1)(f) of the Financial Advisers Act 2001 read with regulation
27(1)(d) of the Financial Advisers Regulations (Rg. 2) except those which only provide advice
by issuing or promulgating research analyses or research reports, whether in electronic, print or
other form, concerning any investment product.
[MAS Notice 314 (Amendment) 2022]

8. Persons exempted under section 99(1)(h) of the SFA read with paragraph 7(1)(b) of the Second
Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations.

[MAS Notice 314 (Amendment) 2022]

9. Approved trustees approved under section 289 of the SFA.

[MAS Notice 314 (Amendment) 2022]

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10. Trust companies licensed under section 5 of the Trust Companies Act 2005.

[MAS Notice 314 (Amendment) 2022]

11. Direct life insurers licensed under section 8 of the Insurance Act 1966.

[MAS Notice 314 (Amendment) 2022]

12. Insurance brokers registered under the Insurance Act 1966 which, by virtue of such registration,
are exempted under section 23(1)(c) of the Financial Advisers Act 2001 except those which only
provide advice by issuing or promulgating research analyses or research reports, whether in
electronic, print or other form, concerning any investment product.

[MAS Notice 314 (Amendment) 2022]

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