COREDO – EU Legal & Compliance Services Expert legal consulting, financial licensing (EMI, PSP, CASP under MiCA), and AML/CFT compliance across the European Union. Headquartered in Prague, we provide seamless regulatory solutions in Germany, Poland, Lithuania, and all 27 EU member states.
Alena Mach
09.01.2026 | 6 min read
Updated: 15.10.2026
Why don't Singapore banks accept European AML documentation? Usually the issue is not where the documents come from but that the file was built for different rules. A Singapore bank reviews a customer under the AML requirements of MAS Notice 626 and the MAS guidelines to it.
A refusal or a long pause in onboarding means the bank still has questions that the file does not answer. It may be a copy without certification, a document without a translation, an unclear beneficial owner or an unclear purpose for an account in Singapore.
Below: what the regulator requires, where a European file departs from it and what to prepare in advance.
Success depends not on the number of documents but on whether the bank can itself verify from them the company, its structure, beneficial owners and source of funds.
What MAS Notice 626 requires from banks
MAS Notice 626 sets binding anti-money laundering and counter-terrorist financing rules for all banks in Singapore. The current version is dated 28 March 2024 and was last revised on 30 June 2025. MAS issued it under the Financial Services and Markets Act 2022 (FSM Act) and issued Guidelines to it.
The concept of criminal proceeds comes from the CDSA, the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992. If a bank has reasonable grounds to suspect that a customer's funds are proceeds of crime, it does not open the account and files a suspicious transaction report (STR).
The core requirement is to verify the customer using reliable, independent sources. For a company, the bank verifies its legal form, proof of existence, constitution and powers. It must also understand the nature of the business, the ownership and control structure and the purpose of the relationship. As a rule, verification is completed before the account is opened, and if it cannot be completed, the bank does not start the relationship.
Notice 626 allows a relationship without a face-to-face meeting, but such verification must be at least as robust as with a meeting. The bank may therefore request additional confirmations or a meeting with the directors and beneficial owners. Whether remote verification is possible depends on the individual bank.
Where a European file departs from the bank's expectations
A European KYC package is usually assembled for a bank or service provider within the EU. For a bank in Singapore these are foreign documents, and it assesses them under MAS requirements and its own policy.
Take the qualified electronic signature. Under Regulation (EU) No 910/2014 (eIDAS), it has the equivalent legal effect of a handwritten signature and is recognised in all EU Member States. This recognition does not automatically extend to Singapore, and acceptance of an electronic document depends on the bank's policy.
The second sticking point is copies. Where there is no original, the MAS guidelines allow a bank to accept a copy certified by a notary public, a lawyer or a certified accountant. The other option is that a bank employee independent of the customer relationship has seen the original. A foreign-language document that matters for the review is translated into English by a qualified translator.
An apostille confirms the authenticity of the signature and seal on a foreign document. The Hague Apostille Convention has applied to Singapore since 16 September 2021. For a document from a Contracting State, including a notarial act, an apostille from the competent authority of the issuing State replaces consular legalisation.
Documents must be current when given to the bank. Neither Notice 626 nor its guidelines set a specific period, so check the acceptable "age" of extracts with the bank in advance.
The bank identifies beneficial owners in a cascade: first the natural persons who ultimately own the company, then those who control it, and only then persons with executive authority. The MAS guidelines give an example threshold: ownership of more than 25% including indirect holdings. A customer's declaration is not enough: the bank itself takes reasonable measures to verify it, for example through public sources or at a face-to-face meeting.
Information from European beneficial ownership registers helps but does not replace this verification. The MAS guidelines also list indicators of higher risk, and for an EU company these matter most:
- a foreign company with no presence or activities in Singapore opens an account there without a clear economic purpose;
- the ownership structure is unusual or excessively complex for the business;
- nominee shareholders or bearer shares;
- a superficial corporate website that does not match the scale of the business.
If the bank cannot see ongoing activity, an economic purpose for the structure or substantive financial activity at the company, Notice 626 requires it to assess the risk. Where the risk is higher, enhanced due diligence measures (enhanced CDD) apply.
Under enhanced due diligence, the bank establishes the source of wealth: the origin of the entire wealth of the customer and the beneficial owner, including seed money and gifts received. It also establishes the source of funds: the activity that generated the specific money for the account, not only the sending bank.
Do not expect a bank in Singapore to accept a review already carried out by a European bank. Notice 626 allows reliance on a third party only under several conditions, including its supervision under FATF standards. Even then the bank remains responsible for the review, and ongoing monitoring cannot be passed on.
How to prepare a KYC file for a bank in Singapore
- Explain the business: why the company needs an account in Singapore specifically, and what transactions, counterparties and amounts to expect.
- Draw the ownership chart up to each ultimate beneficial owner and explain the purpose of each layer.
- Order fresh register extracts for each legal entity in the chain. The data of a Singapore company must match what it has filed with ACRA, including the information on its registrable controllers (RORC).
- Have copies certified, check whether an apostille is needed and have the key documents translated into English.
- Support the source of funds and source of wealth with tax returns, bank statements, audited financial statements or property sale agreements. The MAS guidelines themselves give these examples.
- Prepare the directors and beneficial owners for a video call or a meeting. Complete the tax self-certification: banks collect tax residence information under CRS and separately under FATCA.
Document checklist for a bank in Singapore
| Document | What matters to the bank |
|---|---|
| Certificate of incorporation, articles of association, certificate of good standing or incumbency | Certified copies and an English translation (MAS guidelines, para 6-6-2, 6-6-6, 6-6-7); an apostille if the bank requires one |
| Register extract and share register | Current at the date of submission and consistent with the ownership chart (MAS guidelines, para 6-6-5, 6-6-5A) |
| Board resolution on opening the account and on the signatories | Confirms the authority of each signatory (Notice 626, para 6.11) |
| Passports of directors, signatories and beneficial owners, proof of address | A clear photograph and legible copies (MAS guidelines, para 6-6-1, 6-6-8) |
| Ownership and control chart | Down to each natural person, with an explanation of each layer (Notice 626, para 6.14, 6.15) |
| Description of the business and of the planned account activity | Purpose of the account in Singapore, counterparties, expected amounts (Notice 626, para 6.18) |
| Evidence of source of funds and source of wealth | Tax returns, statements, audited financial statements (MAS guidelines, para 8-5-7) |
| Tax self-certification (CRS, FATCA) | Tax residence of the company and its owners |
Keep copies of everything you give the bank. The bank retains due diligence data for at least 5 years after the relationship ends and reviews it periodically, so you will need the same documents again.
A bank in Singapore needs an understandable business, not more paper
European AML documentation is not "bad" for Singapore: it answers the questions of a different regulator. A bank in Singapore must itself verify the company, its beneficial owners and the source of funds and understand why the business needs an account here specifically.
If a bank has already refused, do not submit the same package to another bank. First find which element of the review was left unanswered: the structure, a beneficial owner, the source of funds or the purpose of the account.
Why COREDO
Since 2016, COREDO has helped companies through bank onboarding, licensing and AML reviews. We support a Singapore account from the structure analysis to account access.
We:
- analyse the client's profile and structure and select the bank and the type of account;
- assemble the documents to the requirements of the chosen bank, including translations and certified copies;
- arrange a meeting with the bank where one is needed;
- support the bank's review and the answers to its additional requests.
The bank decides on opening the account, and the timing depends on the bank and the completeness of the documents.
Contact the COREDO team: we will check your file before submission and prepare the package for opening a bank account in Singapore.