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INTERSHORES I MAS Fines Three Banks And An Insurer For AML Breaches involving Transactions With Wirecard AG

MAS (Monetary Authority of Singapore) has fined Citibank N.A., Citibank (Singapore), DBS Bank, OCBC Singapore and Swiss Life (Singapore) a combined SGD 3.8 million (US$2.8 million) for breaching its AML/CFT (anti money laundering and countering the financing of terrorism) requirements end June 2023.  The fines were imposed after MAS’s examinations of the financial institutions showing that they had “inadequate AML/CFT controls in place when they dealt with persons who were involved in transactions with, or had links to, Wirecard AG or its related parties.   


The transactions were part of an elaborately orchestrated scheme involving a complex corporate structures, nominee arrangements and financial products to conceal actual control and/or beneficial ownership.  Despite the banks had detected and acted upon some of these activities through transaction monitoring and customer due diligence – and ultimately exited all relevant entities, the banks were unable to unravel the scheme in its entirety.


The Wirecard AG case involved in intricate web of entities and transactions spanning multiple jurisdictions which demonstrates the complexity of global financial crimes.


The three banks were found to have “failed to correctly identify the customers’ beneficial owners” and had also “failed to inquire in to unusually large transactions that had no apparent economic purpose.


As for the insurer Swiss Life, it was fined SGD200,000 for breaches dated back to 2017 relating to an investment-linked life insurance policy.


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