Inter-Ministerial Committee publishes recommendations to strengthen Singapore’s anti-money laundering framework

11 October 2024

On 4 October 2024, the Inter-Ministerial Committee (“IMC”) published a report sharing its findings and recommendations following its review of Singapore’s anti-money laundering (“AML”) framework. The overarching strategy is a whole-of-society approach, in which relevant stakeholders are part of the frontline of defence and work collaboratively with relevant Government agencies.

As explained in a joint media release issued by the Ministry of Home Affairs, the Ministry of Finance (“MOF”), and the Monetary Authority of Singapore (“MAS”), the IMC review, drawing lessons from the major money laundering (“ML”) case in August 2023, was set up to ensure that Singapore’s system remains relevant against increasingly sophisticated criminal tactics. It focused on five key areas:

  • How to better prevent money launderers from misusing corporate structures;
  • How financial institutions can enhance their controls and collaborate more effectively with one another and the authorities to identify and flag suspicious transactions;
  • How other gatekeepers in the system, like corporate service providers, real estate salespersons and estate agencies, and precious stones and precious metals dealers, can better guard against money laundering risks, including the adequacy of the existing regulatory framework over these players;
  • How to better centralise and strengthen monitoring and sense-making capabilities across Government agencies to detect suspicious activities; and
  • How to strengthen enforcement levers and capabilities to enable firm and decisive actions against money launderers, including depriving them of ill-gotten proceeds.

Recommendations

The IMC’s recommendations aim to strengthen the three key prongs underpinning Singapore’s AML framework, i.e. proactive prevention, timely detection, and effective enforcement. Broadly, the IMC’s recommendations are as follows:

  • Proactive prevention: Building on existing AML frameworks to proactively prevent criminals from laundering their illicit proceeds by:
    • strengthening AML standards for gatekeepers;
    • further supporting gatekeepers in enhancing their capabilities to combat ML;
    • engaging non-regulated sectors to enhance their understanding of ML risks; and
    • strengthening mechanisms to deter the misuse of companies.
  • Timely detection: Enabling sector supervisors and gatekeepers in the timely detection of illicit activities by:
    • strengthening sense-making and information sharing within the Government; and
    • deepening channels for data sharing among and with gatekeepers.
  • Effective enforcement: Taking effective enforcement actions against criminals who engage in illicit activities by:
    • enhancing legislative levers for law enforcement agencies to better pursue and prosecute ML offences;
    • continuously reviewing penalty frameworks to ensure that they remain proportionate and dissuasive; and
    • strengthening inter-agency coordination to enable swifter and more effective action against illicit ML activities.

The IMC’s recommendations are the Government’s latest measures to combat ML and other financial crimes. Such crimes will continue to evolve and remain a threat to all international financial centres.

As mentioned in the press release, Singapore will continue to enhance its defences by adopting risk-proportionate measures to detect and deter criminals and safeguard its institutions and systems, while remaining welcoming to legitimate investors and businesses.

Reference materials

The following materials are available on the MOF website www.mof.gov.sg and the MAS website www.mas.gov.sg: