Opening Remarks at Singapore Financial Crime Defence Symposium

The theme of this symposium is fighting financial crime in a more complex world which is reflected by the representation of the audience today and the focus of the speakers and panels.

Many around the world are looking at Singapore right now to judge how the fight is going, not least the FATF which is carrying out its 5th round of country evaluations, though some call it the 2nd round of effectiveness evaluations and as it does it will see that like most places elsewhere the threats have gone up, definitely since last time they assessed Singapore in 2016 and the follow up in 2019 and those threats have evolved and are making the most of a banking, finance, payments, crypto and professional service ecosystem whose products and services and the way they are delivered are unrecognisable now from then, with financial criminals becoming more prevalent, more networked, more international, more wealthy, tech savvier and more confident. They can also outsource their money laundering to professionals, whose ability to use important value transfer corridors means the cost of laundering money is getting cheaper not more expensive.

You all know how risk assessments work if the inherent risk goes up then to keep pace and maintain or better reduce residual risk then the quality and effectiveness of the response needs to go up just to stand still.

I don’t think our risk appetite has grown over time, but the gap is I’m sure bigger than it was before - not because the response isn’t real but because to keep pace with the increase and change in the threat is difficult. Certainly if we didn’t have the level of response which is significant and in particular the effort from those in this room and those you represent the gap would be a chasm.

As T Raja Kumar our keynote speaker, often remarks and he probably will do again today criminals have the advantage at being able to go at the speed of light or flight and across borders whereas we go by the speed of rights.

Last week at the Wolfsberg group annual forum in Switzerland I was invited back to my old stomping ground for its 25 year anniversary and as someone who attended most of these events over the last 20 plus years the people and the topics discussed reflect the changing threats and challenges that are before us here today.

Over 3 days leading banks financial crime heads also from fintechs non trad FI, FIU’s, Law enforcement, regulators, policy makers and civil society grappled with what we should do that’s different from plan A. Whilst FATF is sticking with Plan A they are promoting innovation and the risk based approach not leaving the excluded behind and trying to address the new threats regarding payments and value transfers whilst still continuing with Raja’s key initiative focussing on increasing asset recovery.

Of course Singapore has had its own experience with asset recovery which shows what can be done and is a lesson to many. Also when it came to showcasing new ideas and new initiatives Singapore’s name came up quite a few times last week, including of course COSMIC, the Singapore’s Anti Scam Command and it’s Anti Scam Centre, & the MAS initiative on feedback on STRs, being initiatives that have to become mainstream and have to get genuine and meaningful credit from FATF to help proliferate these elsewhere but more than anything it was Singapore’s all of government approach and outreach to partners with carrot and yes stick where necessary that hit home most and where others have found this the hardest of all challenges.

Whilst a top down approach is essential to provide leadership and present an overall strategy, so is a bottom up approach so that you get priorities and public sector action but also the benefits from innovation and genuine inspired collaboration coming from the private sector. Government alone will never come up with all the new ideas to close the gap and a successful implementation will always involve the private sector so there has to be room for flexibility and for room to take risk based action so long as what works is valued.

These new ways of working reflect a new reality that responses to be effective today are different from those of the past and likely come from a recognition that increased collaboration, use of new technology, and a focus on risk based outcomes versus rules based compliance activities can’t be just at the margins but must become ever more mainstream. The responses to tomorrow’s challenges are coming fast.

You all know AI has the capacity to tilt the scales, whether that’s machine learning which has been used for sometime for example using natural language processing, graph neural networks and deep learning which is enabling deepfakes, but also is behind large language models like Chat GPT, which are also the foundation for Agentic AI, which is where autonomous AI agents act for you including as a consumer including making payments with few guardrails in place. Try asking your TM alert team to call up my future autonomous AI agent that takes decisions based on my programmed preferences and activities and behaviours to quiz it on whether a transaction is suspicious. You see where this is going!

A gap already exists, it’s probably too large, despite important initiatives even in Singapore it’s still too large - you are the people that will determine whether the gap gets bigger or smaller, with knowledge about the threats, the aid of others, the use of data, new technology and the right legal frameworks and incentives.

Listen to the speakers today and engage with them and your colleagues and come away with some new knowledge or contact or action where you can improve your response and be open to working and collaborating with others where this can have bigger impacts.

After all you care about the reputation of Singapore, the reputation of the financial sector and professional services in Singapore but as the FATF founders proclaimed 30 plus years ago it wasn’t about the integrity of the financial system even back then when the financial system was considered in many ways to be on the wrong side. Few would say that now and that’s a victory if that’s the only objective, but it’s not.

As it was then it’s about reducing harms from serious financial crime by reducing financial crime and disrupting financial criminal activity by all means including importantly tackling money laundering.

Singapore was invited to join FATF in 1992 just a few years after its founding as the original G7 members expanded and they knew that financial centres held the key to both being attractive to money laundering and in combatting it. Whilst crimes are committed for financial gain, financial centres will always be an important threat vector but the best ones know that dirty money over time drives good money away and adversely influences society and its institutions.

Singapore is rightly proud of who it is but the fight against financial crime is not what it was and a new wave of threats and challenges are coming as we navigate this more complex world.

John Cusack
Chair, GCFFC
27 May 2025