Singapore is expanding its approach to financial crime detection through COSMIC, a collaborative information-sharing platform designed to help banks identify suspicious activity across institutional boundaries.
As regulators look to broaden its reach, the initiative is placing greater emphasis on the quality of financial institutions’ underlying anti-money laundering (AML) systems and the role of RegTech in supporting cross-bank intelligence sharing. RegTech provider ZIGRAM argues that COSMIC’s effectiveness depends on the strength of participating institutions’ own screening, transaction monitoring and entity risk assessment capabilities. Its analysis highlights the importance of reliable customer data and accurate risk detection in ensuring that shared intelligence helps uncover financial crime rather than generating additional compliance noise.
COSMIC, short for Collaborative Sharing of ML/TF Information & Cases, is Singapore’s first centralised digital platform enabling prescribed financial institutions to exchange specified customer risk information. The Monetary Authority of Singapore (MAS) launched the platform on 1 April 2024 under Part 4A of the Financial Services and Markets (Amendment) Act 2023.
Six banks participated in the initial phase: DBS, OCBC, UOB, Citibank, HSBC and Standard Chartered. The platform focuses on three priority areas: the misuse of legal persons, the abuse of trade finance for illicit purposes and proliferation financing.
COSMIC was established to address a persistent weakness in traditional AML controls: financial institutions often have visibility only into the accounts, transactions and corporate relationships within their own systems. A company operating across several banks may appear relatively low-risk when each institution assesses its relationship independently. When information is connected across those institutions, however, patterns involving shell companies, suspicious trade flows or related counterparties may become clearer.
Through COSMIC, participating institutions can request information from other banks, proactively disclose relevant risk information or publish specified details to platform participants after filing a Suspicious Transaction Report (STR) and exiting a customer relationship.
Information sharing is governed by defined thresholds and strict purpose limitations. Disclosed information must relate to anti-money laundering, countering the financing of terrorism or countering proliferation financing. It cannot be used for marketing or credit decisions.
MAS issued its Guidelines to Notice FSM-N02 on 18 October 2024, setting out expectations for governance, internal approvals, audit trails, role-based access and data quality. Outsourcing provisions followed on 11 December 2024. False or reckless disclosures can attract fines and imprisonment, while breaches of MAS notices can result in fines of up to SGD 1m.
COSMIC’s first-year results point to the potential value of sharing intelligence across financial institutions. During its first 12 months, the platform contributed to 461 additional STRs covering transactions worth more than SGD 1.6bn. Participating banks also closed 1,152 suspicious accounts and identified two illicit networks that institution-level monitoring had missed.
The figures suggest that information sharing can complement existing monitoring systems by helping banks identify connections that may otherwise remain hidden. However, the effectiveness of the approach depends on institutions being able to identify meaningful red flags, assess the information they receive and take appropriate action.
Singapore’s plans for expansion are adding urgency to these requirements. The country’s FATF/APG Mutual Evaluation Report, published on 6 May 2026, recognised COSMIC and recommended extending it to additional financial institutions and risk areas. The Ministry of Home Affairs has also confirmed plans to bring more banks into the initiative, with selected non-bank financial institutions potentially included.
A broader participant base could improve visibility across financial networks, particularly where suspicious activity spans multiple institutions and corporate structures. It would also increase the importance of consistent data standards, secure information handling and effective analytical capabilities.
COSMIC does not replace existing customer due diligence, beneficial ownership analysis or transaction monitoring obligations. Each institution remains responsible for its own AML controls and must independently assess the risks associated with its customers.
One challenge is calibrating the platform’s red-flag thresholds. Criteria that are too broad could generate excessive low-value alerts, increasing pressure on compliance teams. Thresholds that are too restrictive, meanwhile, could allow suspicious activity to go undetected. Differences in data quality, risk appetites and monitoring systems across participating banks add further complexity.
RegTech capabilities such as name screening, transaction monitoring, entity resolution and network analysis can help institutions identify relevant activity before information is shared. They can also support investigations once intelligence from other participants becomes available.
ZIGRAM’s analysis highlights several capabilities that can support this process, including sanctions and adverse media screening, transaction monitoring, beneficial ownership analysis and entity-level risk assessment. Its solutions include PreScreening.io for screening, Transact Comply for transaction monitoring and Entity Hero for entity risk assessment and ownership analysis.
For financial institutions, the challenge is to ensure these systems work together, producing accurate, actionable intelligence while maintaining the governance required for cross-institution sharing. Better data and detection can help reduce unnecessary alerts and make shared information more useful to participating banks.
As Singapore moves towards broader COSMIC participation, the platform offers a model for collaborative financial crime detection, but its success will depend on the quality of the controls supporting it. ZIGRAM’s analysis reinforces the importance of strengthening internal compliance capabilities as institutions prepare for a more connected approach to AML intelligence sharing.
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