What is the financial crime regulation in Asia Pacific’s Payments sector

Regulators in Hong Kong and Singapore are generally more hands on and collaborative with the industry. The Monetary Authority of Singapore (MAS) and the Hong Kong Monetary Authority (HKMA) work closely with firms on shaping regulations and their behaviour. They are also hands-on from a supervisory perspective, with certain regulators requiring direct access to accounts in real-time to make sure firms meet liquidity requirements.

In today's interconnected global economy, the payments sector underpins countless daily transactions and facilitates the seamless flow of capital across borders. The payments industry in APAC has undergone significant change and innovation in the last few years with ISO 20022 migrations, new real-time services, and the explosion of Payments-as-a-Service in the cloud.

Innovation in the payments landscape has undoubtedly brought about huge benefits for consumers - less friction, greater flexibility and almost real-time account balances. Unfortunately, with new channels for criminals to exploit, the growth in digital payments has also ushered in a new era of financial crime risks.

APAC supervisors are taking steps to combat such activity by ensuring payment providers systems and controls meet strict requirements in line with national and international AML regulations.  

Our guide sheds light on pivotal APAC regulatory bodies and their payment and AML regulations in Asia Pacific: The Monetary Authority of Singapore (MAS) and the Hong Kong Monetary Authority (HKMA), Australian Transactions and Reports Analysis Centre (AUSTRAC) and the Australian Treasury.

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• Hong Kong - Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO)  

• Hong Kong - Guideline on Anti-Money Laundering and Counter-Financing of Terrorism  

• Hong Kong - Prevention of Money Laundering and Terrorist Financing Guideline  

• Singapore - Payment Services Act 2019  

• Singapore - Prevention of Money Laundering and Countering the Financing of Terrorism – Specified Payment Services  

• Australia - Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act)  

• Australia - Payment Systems (Regulation) Act 1998  

The Monetary Authority of Singapore (MAS) is the central bank of Singapore. Its mission is to promote sustained non-inflationary economic growth, and a sound and progressive financial centre.  

As part of Singapore’s Smart Nation vision to harness technology and be the leading smart city in Asia, MAS is working to create a ‘Smart Financial Centre’, where fintech and payments innovation is strong. Making payments secure is an important part of this vision.

In 2023, MAS released a Consultation Paper proposing amendments to the Payment Services Regulations 2019, focusing on anti-money laundering, countering the financing of terrorism, digital payment token services, and certain technical aspects. The consultation response was closed in 2024, and the amendments will take effect after a 6-month period.

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The Hong Kong Monetary Authority (HKMA) is Hong Hong’s central banking institution. It ensures monetary stability in Hong Kong, promotes the integrity of its banking system and combats financial crime.  

In July 2023, HKMA's Executive Director (Enforcement and AML) emphasised the growing concern of digital fraud, attributing its rise to the popularity of online-only services and real-time payments among criminals.

In October 2022, HKMA endorsed the "Scameter" tool by the Hong Kong Police Force, designed to alert the public to potential fraud risks in various transactions.

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The Australian Transaction Reports and Analysis Centre (AUSTRAC) is an Australian government agency responsible for preventing, detecting and responding to criminal abuse of the financial system.

AUSTRAC has consistently highlighted the financial crime risks associated with emerging payment methods, noting in 2011 the potential for electronic payment systems to be exploited for money laundering.

In 2024, The Australian Transaction Reports and Analysis Centre (AUSTRAC) released a new financial crime guide on combatting the use of international students as money mules.  

A 2024 money laundering risk assessment emphasised criminal use of digital currency with gaps in AML/CFT regulations concerning new payment types and systems, and strong support for including digital wallets and currencies under AML/CTF regulation.

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The Australian Treasury is the government’s lead economic advisor. It provides advice and implements policies to achieve strong and sustainable economic growth for Australians. As part of its work, it collaborates with other regulatory bodies to develop and implement effective financial crime regulations.  

In 2023, the Australian Government proposed reforms to the Payment Systems (Regulation) Act 1998, drawing insights from global regulatory developments.

The reforms aim to address new financial crime risks in the payments system, emphasising intersections with AML/CFT, cybersecurity, data protection, and national security.

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