Guidelines to MAS Notice FSM-N27 on Prevention of Money Laundering and Countering the Financing of Terrorism — Digital Token Service Providers¶

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Document Type: Guidelines (non-binding but MAS-issued guidance)
Parent Notice: MAS Notice FSM-N27
Issuing Authority: Monetary Authority of Singapore
Issued under: Financial Services and Markets Act 2022 (FSM Act), Part 9
Effective Date: 30 June 2025
Applies to: All holders of a Digital Token Service Licence; guidance to DTSPs on requirements in Notice FSM-N27

Purpose¶

These Guidelines provide detailed guidance to licensed Digital Token Service Providers on implementing the AML/CFT requirements in MAS Notice FSM-N27. They explain how DTSPs should give effect to the Notice's requirements in practice, covering risk-based approaches, due diligence standards, and operational implementation.

Key Guidance Areas (Reconstructed from WebSearch)¶

1. Risk-Based Approach¶

Guidance on how DTSPs should identify, assess, and understand ML/TF risks specific to digital token services
Factors to consider in risk assessments: customer type, geographic risk, product/service type, delivery channel

2. Customer Due Diligence (CDD) Standards¶

Detailed guidance on implementing CDD requirements from FSM-N27
Risk indicators and red flags specific to digital token transactions
Guidance on enhanced CDD (EDD) triggers for higher-risk customers

3. Travel Rule Implementation¶

Guidance on implementing FATF Travel Rule for virtual asset transfers
Information requirements for originator and beneficiary identification

4. Transaction Monitoring¶

Guidance on setting transaction monitoring thresholds and parameters
Typologies and red flags specific to DTSP services

5. Correspondent Relationships¶

Guidance on managing correspondent DTSP relationships
Due diligence standards for correspondent accounts

6. Suspicious Transaction Reporting¶

Practical guidance on identifying and reporting suspicious transactions to STRO

7. Record Keeping¶

Guidance on record retention periods, formats, and accessibility requirements

Regulatory Context¶

MAS issued companion guidelines alongside Notice FSM-N27 as part of the comprehensive DTSP regulatory framework effective 30 June 2025. These guidelines are non-binding interpretive guidance but carry significant weight in MAS supervisory expectations.