Singapore's measures to counter money laundering, terrorist financing and proliferation financing

• Singapore employs a dynamic approach to identifying and assessing money laundering and terrorist financing risks, which has led to a reasonably sound understanding of its risks.
• The country’s open economy, large trade flows, status as an international financial centre and a hub for company formation and wealth management make it attractive to legitimate businesses, foreign criminals, as well as those looking to launder their funds and enjoy them in a stable environment.
• Fraud is Singapore’s most prominent money laundering threat, particularly scams and other cyber-enabled frauds.
• Singapore’s whole-of-government approach is underpinned by extensive domestic co-ordination and co-operation through high-level and working-level committees that ensure cross-agency collaboration, policy alignment, and risk monitoring, supported by subject-specific interministerial committees. There is also active engagement from supervisory authorities and industry associations.
• The Anti-Money Laundering Case Coordination and Collaboration Network (AC3N) and AML/CFT Industry Partnership (ACIP) facilitate inter-agency and public-private collaboration on AML/CFT efforts.

• International co-operation is critical for Singapore as an international financial centre with primary threats located abroad, and Singapore is generally proactive and effective in this area, but a minority of partners identified bureaucratic delays.
• Authorities in Singapore make four times fewer mutual legal assistance requests than it receives, however the country actively engages in informal forms of co-operation, which generally is timely, effective, and aligns with risks to some extent.

• The Monetary Authority of Singapore’s work to ensure that financial institutions and Virtual Asset Service Providers (VASPs) understand ML/TF risks and AML/CFT obligations is a strength of Singapore's system, but overall, the number of enforcement actions remains relatively low.
• Singapore has, since its last mutual evaluation, developed into one of the most significant virtual asset services providers hubs in the world. It has a robust licensing framework in place to ensure that criminals and their associates are not beneficial owners or hold controlling interests in financial institutions and virtual asset service providers.

• The Accounting and Corporate Regulatory Authority in Singapore has implemented a beneficial ownership registry for all legal persons, except Variable Capital Companies and Unregistered Foreign Companies, however there are limited mechanisms to ensure the information on the registry is accurate.

• Singapore’s FIU, the Suspicious Transaction Reporting Office (STRO), is well resourced and leverages sophisticated systems to produce financial intelligence. Although there is some ambiguity about the FIU’s operational independence, that did not have an observed effect on STRO’s ability to conduct its business.
• Competent authorities have access to a broad spectrum of reports, data and information, including financial intelligence.
• Financial intelligence from the STRO is being used to initiate and support investigations into money laundering, associated predicate offences and TF to a good extent but more could be done to leverage financial intelligence for higher risk offences other than fraud.

• Singapore’s law enforcement agencies opened over 11,000 money laundering investigations in the last 5 years, with over 80% being initiated from victims’ complaints in relation to cyber-enabled fraud.
• The assessment found that there are significantly fewer investigations into other higher-risk areas like tax crimes, corruption and trade-based money laundering.
• Singapore has experienced challenges converting investigations into prosecutions.  Legislation has been introduced to facilitate the prosecution of money laundering cases, but these changes are recent and their impact remains to be established.
• Overall, Singapore achieves a good conviction rate (82%), including in complex cases, although the majority of sanctions are made for low-level money mule cases, rather than professional syndicates, professional intermediaries, and legal persons.

• Asset recovery is a high-level political priority, supported by the National Asset Recovery Strategy and Singapore’s whole-of-government approach.
• Law enforcement agencies actively freeze and seize criminal property, seizing close to SGD 6.3 billion (USD 4.7 billion) over the reporting period. These results were largely driven by a small number of high-value, complex cases.
• Singapore achieves a positive seizure to confiscation rate (61 %) and has obtained a significant amount of confiscation: SGD 3.9 billion (USD 2.9 billion) between 2020 and 2024.
• Authorities make active use of informal co-operation but there is scope to improve formal international co-operation for asset recovery.
• Singapore has a solid legal cross border cash reporting regime framework, but there are weaknesses in the identification of breaches and linking them to suspicions of money laundering. 

• Singapore has opened 126 terrorist financing investigations into 213 natural and legal persons over the past five years. From these investigations, they have prosecuted six cases.
• All TF prosecutions in Singapore exhibit the same typology which involves individuals sending small amounts of their salary overseas to support global terrorist activities.
• While this is largely in line with Singapore’s risk and context, there is an absence of counter-terrorist financing activity in relation to funds transiting through Singapore via the banking sector or digital payment token service providers, which has been identified by Singapore as one of its highest terrorist financing risks.

• A number of factors make Singapore one of the jurisdictions most vulnerable to proliferation financing: its geographical position, and its status as an international financial centre, and a hub for trade, transport, maritime and virtual assets.
• Singapore has a strong legal framework for PF TFS obligations, with the AML/CFT Steering Committee providing co-ordination and policy leadership allowing Singapore to convene quickly to discuss PF issues and co-ordinate as needed.
• The risk mitigation measures as set out in Singapore’s Counter-Proliferation Financing Strategy are general, not proportional to risk, and largely already being conducted as part of the jurisdictions counter-proliferation financing regime. Singapore’s proliferation financing national risk assessment also highlights risk areas that have no or negligible mitigation measures identified.
• Noting Singapore’s status as a maritime hub, the assessment found that representation offices of foreign flag States which offer so-called ‘flags of convenience’ to the shipping industry, have a very low awareness of their proliferation financing targeted financial sanctions obligations.
• Singapore’s supervisors should more appropriately cover their financial institutions, virtual asset service providers and designated non-financial businesses and professions supervisors PF TFS obligations.

Following the assessment, Singapore received a roadmap of Key Recommended Actions to complete within three years, such as enhancing transparency for complex arrangements and Unregistered Foreign Companies, prioritising complex high-value money laundering investigations and implementing more context-specific proliferation finance risk mitigation measures including for representative offices of foreign flag States.

Based on Effectiveness and Technical Compliance Ratings, Singapore is placed in regular follow-up. Singapore will report back to the FATF and APG on its progress.