The industry led AAPG was established in October 2022 to facilitate AML/CFT audit best practices in Singapore’s financial industry, and to promote engagement with the Monetary Authority of Singapore (MAS) and the wider audit community on key AML/CFT risk areas.

It was formed in recognition that both internal audit functions and external audit firms play key roles in ensuring that financial institutions’ internal policies, procedures and controls remain adequate to combat money laundering and terrorism financing risks, and to stay ahead of the constantly evolving risk landscape.

DBS and OCBC are the current Co-Chairs of the AAPG. Other members of the AAPG are:

• Citibank Singapore
• Goldman Sachs (Singapore) Pte.
• GXS Bank Pte. Ltd.
• HSBC Bank (Singapore) Limited
• MariBank Singapore Private Limited
• Standard Chartered Bank (Singapore) Limited
• UBS AG Singapore Branch
• United Overseas Bank Limited
• BDO LLP
• Deloitte and Touche LLP
• Ernst and Young Advisory Pte. Ltd.
• Forvis Mazars LLP
• KPMG LLP
• PricewaterhouseCoopers LLP
• The Institute of Internal Auditors Singapore
• The Institute of Singapore Chartered Accountants

MAS participates in the AAPG’s discussions as an observer.

AAPG Best Practice Paper – Enhancing AML/CFT Audit Effectiveness for Banks

Objective of the Paper

This paper aims to set out baseline standards and best practices for internal and external auditors to consider when determining the appropriate scope and extent of testing in the conduct of AML/CFT audits for banks.

This paper brings together the practices of AAPG members, as well as inputs from banks and audit firms that contributed to the AAPG’s benchmarking survey in 2023. The survey solicited inputs on several aspects of audit practice, including:

• AML/CFT audit coverage;
• AML/CFT audit approach; and
• use of data analytics (“DA”) and new techniques to strengthen AML/CFT audit effectiveness.