Singapore: A Corporate Investigations/Anti-Corruption: Domestic Overview

As an international trade, transport and financial hub, Singapore faces exposure to financial threats such as money laundering, terrorism financing and financial scams. According to a joint report released by various enforcement agencies in Singapore, SGD6 billion that was linked to criminal and money laundering activities was seized by the enforcement agencies from January 2019 to June 2024. The Singapore Police Force (SPF) also reported that the total amount lost to financial scams in 2024 was SGD1.1 billion. The relevant authorities have introduced various measures to strengthen Singapore’s capacity to address such threats, including:

• the imposition of new anti-money laundering and counter-terrorism financing (AML/CFT) obligations on various at-risk sectors in Singapore;
• the enhancement of information-sharing tools to facilitate detection of AML/CFT risks;
• the creation of new offences to address money laundering;
• the enactment of legislation to guard against financial scams; and
• amendments to the Mutual Assistance in Criminal Matters Act 2000 (MACMA) to enhance the framework for international assistance in criminal matters and extradition.

New AML/CFT Obligations To Combat Money Laundering Risk

In 2024, the Monetary Authority of Singapore (MAS) issued the Money Laundering Risk Assessment Report 2024, which identified, among other things, that corporate service providers (CSPs) and real estate sectors faced heightened money laundering risks. In the context of CSPs, foreign criminal elements typically obscure their identities by recruiting nominee directors when incorporating shell companies in Singapore to meet regulatory requirements. These shell companies are then used to conduct illicit funds transfers. As for the real estate sector, criminal elements commonly convert their criminal proceeds into real estate.

To address these risks, the Corporate Service Providers Act 2024 was recently enacted, which stipulates that business entities providing corporate services are required to register with the Accounting and Corporate Regulatory Authority of Singapore, failing which they would not be allowed to operate. CSPs are also required to apply customer due diligence (CDD) measures in each of the following instances:

• before providing any corporate service to a customer;
• where the CSP has reason to suspect money laundering, proliferation financing or terrorism financing; or
• where the CSP has reason to doubt the veracity or adequacy of information obtained from earlier CDD measures performed.

If CDD measures cannot be satisfactorily completed, the CSP must decline to provide corporate services to the customer, terminate any ongoing provision of corporate services and consider whether to file a suspicious transaction report (STR).

Furthermore, the Estate Agents Act 2010 was amended to require estate agents and salespersons to apply CDD measures not only in relation to their own clients, but also in respect of other unrepresented counterparties in property transactions:

• if there is reason to suspect money laundering, proliferation financing or terrorism financing; or
• where there is reason to doubt the veracity or adequacy of information obtained from earlier CDD measures.

Enhanced Information Sharing To Better Detect AML/CFT Risks

Information sharing between the relevant authorities and stakeholders has been strengthened to better detect AML/CFT risks and potentially illicit assets, so that investigations may be commenced in a timelier manner.

In this regard, in April 2024, the MAS and six major commercial banks in Singapore launched a digital platform, COSMIC (Collaborative Sharing of Money Laundering/Terrorism Financing Information & Cases), to allow financial institutions (FIs) to securely share information on customers who exhibit “red flags” that may indicate potential financial crime concerns with one another, if stipulated thresholds are met. With COSMIC, it would be easier for FIs to detect suspicious activities and thereby deter criminal activity.

Further, the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 (CDSA) was amended to allow the Suspicious Transaction Reporting Office (STRO) to disclose STRs to other regulators, such as the Inland Revenue Authority of Singapore. Amendments were also made to the Goods and Services Tax Act 1993, Income Tax Act 1947, and Regulation of Imports and Exports Act 1995 such that the respective comptrollers may share information with the STRO to detect the possible commission of offences. Such data sharing will enhance the STRO’s ability to analyse money laundering risks and provide better intelligence to the relevant authorities.

Creation of New Offences To Combat Money Laundering

Two new money laundering offences (ie, the offences of “rash” and “negligent” money laundering) were introduced, which allow enforcement agencies to prosecute persons for money laundering at lower levels of culpability and apply to persons acting as directors of companies or operating corporate accounts. This means that individuals and businesses can no longer claim ignorance of the illicit nature of a transaction where there are clear AML/CFT red flags.

Additionally, serious foreign environmental offences (such as illegal logging or mining) have been designated as money laundering predicate offences through amendments made to the CDSA. These amendments plug a gap in Singapore’s money laundering regime, which previously allowed law enforcement agencies to only investigate money laundering offences arising from the commission of a foreign offence if the offence is also a serious offence under Singapore law. Prior to these amendments, no such environmental offences had been designated as serious offences under Singapore law.

Lowered Evidential Threshold for the Prosecution of Money Laundering Offences

The CDSA was also amended to enable easier prosecution of money laundering offences. In this regard, it is now sufficient for the prosecution to show, beyond reasonable doubt, that the accused knew or had reasonable grounds to believe that the monies were criminal proceeds; there is no longer a requirement for the prosecution to show the complete money trail from the victim to the money launderer to prove that the monies are in fact benefits from criminal conduct. This amendment addresses the difficulties in evidence gathering, especially where funds have flowed through many jurisdictions before entering Singapore.

Guarding Against Scams

Separately, measures have been introduced to guard against financial scams that may facilitate money laundering. A typical typology of a scam involves deceiving victims into receiving tainted proceeds in their bank accounts without knowledge of their illicit origin and thereafter instructing them to transfer these funds to other “pass-through” accounts via a remittance service or wire transfer.

To address this, the Protection from Scams Act 2025 was enacted in February 2025 to enable the SPF to better protect targets of ongoing scams by empowering them to issue restriction orders to banks to restrict the banking and credit facilities of an individual, if there is reasonable belief that the individual will make money transfers to scammers with the intention of giving the money to the scammer, or apply for or draw down on any credit facility with the intention of benefitting the scammer.

Punishment for scam-related offences has also been enhanced. Scammers now face mandatory caning of at least six strokes (up to 24 for severe cases), while money mules and others who assist scam syndicates will face discretionary caning of up to 12 strokes.

Enhancing Transnational Co-operation

Finally, a strong international co-operation framework is vital in tackling transnational crime (including money laundering/terrorism financing). In this regard, amendments have been made to MACMA to allow statements to be taken from persons for the purpose of assisting foreign criminal investigations. The scope of property that can be frozen, seized or confiscated under MACMA has also been expanded to include property that was intended to be used in the commission of a foreign offence (at present, only property that was used in the commission of a foreign offence may be frozen, seized or confiscated under MACMA).

Notable Developments

Other notable developments in 2024 and 2025 include the following.

• The first Deferred Prosecution Agreement (DPA) in Singapore: In July 2025, Seatrium Ltd announced that it had entered into a DPA with the Attorney-General’s Chambers (AGC) in relation to alleged corruption offences in Brazil. Under the DPA, Seatrium Ltd agreed to pay a financial penalty of USD110 million to the AGC, and undertook to review and strengthen its ethics and compliance programme. The DPA is currently pending an application to the Singapore High Court for approval.
• Affirmation of the Tom-Reck test for corporate attribution: In Public Prosecutor v China Railway Tunnel Group Co. Ltd. (Singapore Branch) [2025] SGHC 101, the General Division of the Singapore High Court affirmed that the wrongful acts or guilty knowledge of a director may only be attributed to the company if he/she can be regarded as the “embodiment of the company” or, if the person is only “the company’s servant”, the person’s acts are “within the scope of a function of management properly delegated to him”. In so ruling, the Court rejected the “reasonable practicability” exception as a defence under the Prevention of Corruption Act 1960. Under this exception, an employee’s wrongdoing will not be attributed to the company if it had taken all reasonably practicable steps to prevent its employees from carrying out corrupt acts.
• Strengthening investor protection: In October 2025, MAS released a consultation paper concerning proposed measures to enforce investor resource avenues in market misconduct cases. Such proposed measures include the introduction of an independent third party as a designated representative to bring legal action on behalf of investors, and the establishment of a grant scheme to co-fund meritorious investor action. The consultation is ongoing as at the date of this article.

Concluding Remarks

The abovementioned developments demonstrate that Singapore remains vigilant against money laundering, terrorism financing and financial scams, as a national priority is maintaining Singapore as a safe and resilient financial centre. To navigate this evolving landscape, businesses should proactively invest in robust internal controls, assess their potential AML/CFT risks and, if necessary, take steps to enhance them.

*Exceline Darmawan, practice trainee, assisted with the research for this article.