The updated draft comes as a follow-up to the revealed “New Payments Framework”, which was announced in the initial draft. It sheds more light on the position of MAS regarding the way certain actors are to monitor its guidelines on the basis of AML and CFT policies.
Such actors are almost any parties connected to the ICO-related activities, ranging from token issuers to token trading facilitators to financial consult providers, thus subjecting everyone to comply with the law. For example, a token issuer is obliged to acquire a license for capital markets services, financial consult providers are required to obtain a corresponding license for their services from the FAA, and cryptoexchanges are to receive approval and acknowledgement from the MAS.
The New Payments Framework provides a clarification regarding all such actors’ liability to make due efforts as to the identification, assessment, and understanding their ML/TF risks. The policies subject them to devise and introduce internal regulations as supervised by the MAS, ensuring due diligence of the customers and regulatory compliance.
MAS policies point out that even in the event that a token is not deemed a security, there is still the necessity of its establishment of compliance with anti-money laundering and CFT acts, meaning their obligation to report any questionable activities and their legal responsibility for collaborating with people or groups determined as terrorists in accordance with the United Nations and the intel agencies of Singapore.