COSMIC’s Expansion: A Working Blueprint for Network-Based AML

On 6 May 2026, the Financial Action Task Force published its mutual evaluation of Singapore’s anti-money laundering framework. The result was strong overall – Singapore was placed in Regular Follow-up, FATF’s best monitoring tier, an upgrade from its 2016 rating – but the evaluation drew a clear line under one shortfall: the regime needed to be “sharper in producing demonstrable and consistent risk-based results.”

Singapore’s response came the same day. The Monetary Authority of Singapore committed to widening COSMIC, its cross-bank information-sharing platform. The expansion will cover a broader set of cases and bring in banks beyond its original six. What MAS did not say was when, or which banks.

That single commitment is the clearest live test yet of an idea most banks still treat as theoretical. Financial crime risk, it implies, should be assessed at the level of the network, not the jurisdiction.

What COSMIC Actually Does

MAS launched COSMIC on 1 April 2024 with six major banks: DBS, OCBC, UOB, Citibank, HSBC and Standard Chartered Bank. Participation is voluntary.

The mechanism is simple: a bank flags a customer showing multiple red flags to other member banks. That closes a blind spot no single institution can see alone: a customer unremarkable in one bank’s data but moving money across several.

Loo Siew Yee is MAS’s Assistant Managing Director for Policy, Payments and Financial Crime. At launch, she said the platform would “enable FIs to warn each other of suspicious activities.” That, she added, would support faster, better-informed risk assessments across the industry.

Coverage has so far been narrow by design: three risk categories, misuse of legal persons, misuse of trade finance and proliferation financing, and six banks. Scam-network typologies are not among them yet.

Why FATF Forced the Issue

FATF’s review found Singapore’s AML regime capable and well-coordinated, willing to try new solutions ahead of its regional peers. But it drew a clear line under one shortfall. Results were not yet sharp or consistent enough to prove the system’s effectiveness, not just its design.

That finding has a concrete backdrop. In July 2025, MAS imposed S$27.45 million in penalties on nine financial institutions tied to the S$3 billion money-laundering case uncovered in 2023 – the second-largest AML enforcement action in Singapore’s history.

It is exactly the kind of case FATF’s evaluators would weigh when judging whether risk-based outcomes are demonstrable and consistent, not just well-designed on paper.

Widening COSMIC is Singapore’s direct answer to that specific finding. It is not a broader package of reform, but a targeted move to close the exact gap FATF identified.

The Gap Between Commitment and Execution

What MAS has not specified matters more, for planning purposes, than what it has. No published timeline. No named banks beyond the original six. No confirmation that expanded participation will stay voluntary.

A platform’s value is a function of its coverage, and an incomplete roster is a real constraint, not a footnote.

The Limit Even a Working Model Has

COSMIC also carries a structural limit that becomes more consequential the more it succeeds: it is a domestic tool. It closes blind spots between banks operating inside Singapore.

It does nothing for the blind spot between Singapore and the other jurisdictions the same criminal network moves through. That gap is the argument at the centre of the companion piece, An Organised Crime Economy That Ignores Borders. For any risk officer deciding how much weight to place on a single jurisdiction’s AML upgrade, it is essential reading.

Widening COSMIC strengthens one node in a network built to ignore borders. It does not connect the nodes. For risk committees outside Singapore, the useful question is not whether Singapore’s model is good enough to copy. It is why no equivalent platform exists anywhere else the network operates.

Infographic: What COSMIC Covers and What It Doesn’t

COSMIC currently operates under the Financial Services and Markets (Amendment) Act 2023. That law sets the legal basis for banks to share customer information without breaching confidentiality duties, provided stipulated red-flag thresholds are met.

The three founding risk categories are misuse of legal persons, misuse of trade finance for illicit purposes, and proliferation financing. Scam-network typologies of the kind described in the main piece are not among them.

The six founding banks, DBS, OCBC, UOB, Citibank, HSBC and Standard Chartered Bank, co-developed the platform with MAS and were its first participants. MAS’s 6 May 2026 statement commits to adding “other major banks” without naming them.

Participation remains voluntary. That single fact determines whether COSMIC’s expansion becomes an industry standard or an opt-in exercise.