T Raja Kumar: What Will the New FATF President Prioritize?

Following the announcement that the next President of the Financial Action Task Force (FATF) will be Singaporean T Raja Kumar, we take a closer look at what this may mean for the FATF’s priorities during his tenure. To do this, we’ve reviewed his prior experience, areas where the Monetary Authority of Singapore (MAS) has been a global innovator, and priorities announced by the FATF at the March plenary.  

The appointment of Mr. Raja as FATF President for 2022-24 – the first time a representative from Singapore has assumed this role – was announced at the organization’s March plenary. Mr. Raja is a senior advisor at Singapore’s Ministry of Home Affairs and head of Singapore’s FATF delegation. 

From Law Enforcement to Regulator 

Mr. Raja has played a crucial role in Singapore’s anti-money laundering and countering the financing of terrorism (AML/CFT) efforts, serving as Co-chairman of the National Interagency Committee on AML/CFT since January 2015, and has driven Singapore’s efforts to meet FATF Standards. He co-led Singapore’s FATF 4th round Mutual Evaluation in 2016.

He also has more diverse experience in the areas of policy, regulation and law enforcement than his predecessor, Dr Marcus Pleyer, who, before becoming FATF president, held a number of roles within Germany’s Finance Ministry and Federal Chancellery.

Mr. Raja was Deputy Secretary (International and Training) at Singapore’s Ministry of Home Affairs, and Deputy Commissioner (Policy) of the Singapore Police Force.

He was also formerly Chief Executive of the Casino Regulatory Authority, an area where the FATF has issued specific guidance. 

As a result, we may see an extension of the FATF’s existing work on high-risk corporates outside the traditional banking/finance sectors. Regulators, including AUSTRAC, have been pursuing high-profile AML cases against casinos in recent months. 

MAS Innovations

Singapore’s Minister for Finance, Lawrence Wong, has hinted that one focus for Mr. Raja could be collaboration between law enforcement, the financial sector, private sector and others. This would be consistent with the approach MAS has taken in Singapore in relation to data and intelligence sharing.

Mr. Wong said in a statement: “I look forward to Raja, as President, bringing together law enforcement authorities, financial sector and other AML/CFT supervisors, as well as private sector stakeholders to achieve effective outcomes.”

Some recent steps from MAS that could form pillars of Raja’s presidency include information sharing and virtual asset service provider (VASP) regulation – key issues in the in-tray of the President and an area where MAS in particular has been very active. 

Another critical topic has been payment service regulation, where MAS has worked to implement stringent regulation without stifling FinTech innovation. Significantly, Singapore’s Payment Services act (PSA) was also amended in 2019, in alignment with FATF standards, to cover e-money and digital payment token services. 

FATF Priorities

The FATF March Plenary at which Raja’s appointment was confirmed also included a number of strategic initiatives related to beneficial ownership, migrant smuggling, real estate and unintended consequences, all of which could shape Mr. Raja’s term.

Beneficial ownership is likely an unavoidable area of focus, with many regulators already taking action. The Philippines’ Anti-Money Laundering Council (AMLC) issued guidance in September 2021 to banks and financial institutions to include the identities of beneficial owners or account holders in their suspicious transaction reports. And Singapore tabled the Corporate Registers (Miscellaneous Amendments) Bill, including amendments intended to reduce the risk of corporate entities being used for illicit purposes.

Mr. Raja says his appointment is the culmination of years of hard work by Singapore’s FATF team. “My deepest appreciation goes to my colleagues from across the Government for their collective work – building the Singapore brand and paving the way for this milestone for Singapore,” he said.

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