In Singapore, Corporate Service Providers (CSPs) are required to conduct AML screening as part of their Customer Due Diligence (CDD) obligations. These requirements are primarily derived from two key regulatory documents:
- Corporate Service Providers Regulations 2025
- AML/CFT Guidelines for Corporate Service Providers (effective from 9 June 2025)
The following explains the requirements from three perspectives: regulatory obligations, official guidance, and practical implementation challenges.
1. Core Regulatory Requirements
First, according to Regulation 22 of the Corporate Service Providers Regulations 2025, the law clearly sets out the requirements for customer screening:
Customer screening
22.—(1) A registered corporate service provider (X) must screen every customer and every agent, connected party and beneficial owner of a customer or, where the transaction relates to the formation of corporations or other legal persons for a customer, every agent, connected party and beneficial owner of the proposed corporation or legal person —
(a) against any lists and information provided by the Registrar and any relevant law enforcement authority; and
(b) against any other source of information relating to money laundering, proliferation financing or terrorism financing, as the Registrar may direct.(2) X must also carry out the screening described in paragraph (1) to —
(a) determine if the customer or any agent, connected party or beneficial owner of that customer is a designated person as defined in any regulations made under the United Nations Act 2001; and
(b) assess whether the customer or any agent, connected party or beneficial owner of that customer is a terrorist or terrorist entity under the Terrorism (Suppression of Financing) Act 2002.(3) X must document the results of the screening of, and any determination made by X concerning the risks of money laundering, proliferation financing or terrorism financing in relation to, a customer or any agent, connected party or beneficial owner of a customer.
From the regulation above, several key compliance requirements can be identified.
First, the scope of screening subjects is extensive. It includes not only the customer but also the customer’s agents, connected parties, and beneficial owners. When the transaction involves the incorporation of a new entity, the screening must also cover the relevant parties of the proposed corporation or legal person.
Second, CSPs are required to screen against multiple information sources, including lists issued by regulators, law enforcement authorities, and other sources relating to money laundering, terrorism financing, or proliferation financing.
Third, CSPs must document the screening results, including any conclusions or risk assessments made based on those results.
2. Further Clarification from ACRA Guidelines
The AML/CFT Guidelines for Corporate Service Providers (2025) provide more detailed interpretation and operational guidance for the regulatory requirements.
6.23 As set out in regulation 22 of the Regulations, a registered CSP must “screen every customer and every agent, connected party and beneficial owner of a customer or, where the transaction relates to the formation of corporations or other legal persons for a customer, every agent, connected party and beneficial owner of the proposed corporation or legal person –
(a) against any lists and information provided by the Registrar and any relevant law enforcement authority; and
(b) against any other source of information relating to money laundering, proliferation financing or terrorism financing, as the Registrar may direct.”6.24 A registered CSP must also carry out the screening described in paragraph 6.23 to –
(a) determine if the customer or any agent, connected party or beneficial owner of that customer is a designated person as defined in any regulations made under the United Nations Act 2001; and
(b) assess whether the customer or any agent, connected party or beneficial owner of that customer is a terrorist or terrorist entity under the Terrorism (Suppression of Financing) Act 2002.6.25 For the purposes of screening against the relevant individuals and entities, a registered CSP is to subscribe to the following MAS’ website on targeted financial sanctions, and to receive alerts to changes to the abovementioned lists:
In addition to persons listed in the First Schedule of the Terrorism (Suppression of Financing) Act 2002 (Cap. 325) (TSOFA), registered CSPs are to review and conduct screening of existing business relations and transactions of individual named in the Alert List of Persons Involved in Terrorism or Terrorism Financing Activities that the Registrar circulates on a regular basis.
6.26 A registered CSP is to obtain more information about terrorist designation and the legislation for countering of terrorism, and subscribe to updates at the Inter-Ministry Committee on Terrorist Designation website at:
https://www.mha.gov.sg/what-we-do/managing-security-threats/countering-the-financing-of-terrorism6.27 A registered CSP should check for any adverse news on the customer using free public search tools, commercial databases or other relevant sources on combatting money laundering and financing of terrorism. The output of screening shall be factored in the customer risk assessment performed by the registered CSP. A registered CSP must document the results of the screening of, and any determination made concerning the risks of ML/PF/TF in relation to a customer or any agent, connected party or beneficial owner of a customer. For example, screenshots or printouts of the search results should be retained to evidence that screening had been performed. For registered CSPs with ongoing business relationships with the customers, the registered CSP shall screen the customers on a periodic basis on a risk-sensitive basis, based on the customer risk assessment performed by the registered CSP, or when there are any changes or updates to the lists and information provided by the Authority or other relevant authorities in Singapore.
3. Key Compliance Expectations Highlighted by the Guidelines
From the official guidelines above, several important compliance expectations can be summarized.
First, CSPs must screen against specific sanctions and terrorism-related lists, including sources such as:
- MAS Targeted Financial Sanctions Lists
- Terrorism (Suppression of Financing) Act lists
- ACRA Alert Lists
- MHA Terrorist Designation Lists
These lists form part of the required screening scope.
Second, CSPs are required to conduct Adverse News screening. According to the guidelines, this may involve the use of:
- Free public search tools (such as Google)
- Commercial databases
- Other relevant information sources related to AML/CFT
The results of these searches must be incorporated into the Customer Risk Assessment.
Third, CSPs must retain evidence of the screening process, such as:
- Screenshots of search results
- Printed search records
- Internal evaluation notes
These records serve as proof that the screening procedures were properly carried out.
Fourth, CSPs must perform ongoing monitoring for customers with continuing business relationships. This means screening must be repeated:
- Periodically based on the customer’s risk profile, or
- Whenever new sanctions lists or relevant regulatory updates are issued.
4. Practical Challenges When Using Only Free Search Tools
In practice, if CSPs rely solely on free public search tools such as Google, several challenges arise.
First, coverage of risk information is incomplete. Free search engines cannot comprehensively cover all relevant sanctions, regulatory, and law enforcement lists.
Second, search results contain a large amount of irrelevant information, making manual analysis time-consuming and inefficient.
Third, Adverse News searches may be affected by geographical bias. Search results are often localized based on the user’s location, which means negative news about foreign clients may not appear prominently.
Fourth, ongoing monitoring becomes difficult to perform manually, as regulatory lists and news sources are updated frequently.
5. Documentation of Screening Results
One of the key focus areas during ACRA compliance reviews is whether screening results have been properly documented.
In practice, regulators often expect CSPs not only to retain screenshots or printouts, but also to document:
- Whether a result is a True Hit
- Whether it is a False Hit
- The reasoning and risk assessment behind the determination
If screening results are not properly documented, CSPs may be unable to demonstrate that proper screening procedures were conducted. This can complicate ongoing monitoring processes and may be considered a weakness in AML/CFT controls during regulatory reviews.
6. Practical Recommendation: Using Professional AML Screening Databases
To efficiently meet these regulatory requirements, many CSPs choose to use professional AML screening databases.
For example, AlgoCandy AML Screening provides a compliance-focused screening solution designed specifically for regulatory requirements.
AlgoCandy’s screening data sources cover global PEP databases, sanctions lists, and Adverse News sources, helping CSPs address the official screening requirements described above.
The system also supports True Hit / False Hit documentation, allows users to add risk assessment notes, and enables the export of comprehensive screening reports for compliance records and regulatory audits.
In addition, AlgoCandy’s data sources are continuously updated using AI-driven monitoring technology, which tracks global sanctions list updates and continuously captures adverse news from public sources. Through the platform’s Ongoing Monitoring functionality, users receive timely alerts when new risk information appears, enabling CSPs to respond promptly, manage emerging risks, and maintain ongoing compliance with regulatory expectations.