In more detail
CCCS' investigations
The CCCS commenced investigations into an immigration consultancy business after receiving multiple consumer complaints regarding misleading sale tactics. Upon discovering the mastermind behind the unfair trade practices, the CCCS then shifted its focus to other immigration consultancy businesses directed by the same individual.
The CCCS’ investigations uncovered the following:
- After potential customers completed forms online to check their chances of obtaining permanent residency (PR), they would be invited for “free consultations". During these consultations, sales staff would make unsubstantiated claims about rapidly changing PR rules and intense competition from other applicants to try to persuade customers to apply as soon as possible.
- Sales staff would also make baseless guarantees of PR application approval if customers engaged their services.
The CCCS found that there was no reasonable basis for the businesses to make these claims or guarantees, and deemed these actions to be unfair trade practices under the Consumer Protection (Fair Trading) Act 2003 (CPFTA).
The investigations also revealed that the individual responsible for directing the operations of the businesses was deliberate in implementing the misleading practices. The individual personally wrote scripts on what staff members needed to do or say to prospective customers; monitored staff’s sales tactics through CCTV footage; and implemented a punishment-and-reward system to enforce his staff’s compliance with such misleading practices.
Further, the CCCS found that the individual continued to operate through their other businesses to evade detection, despite ongoing CCCS investigations into some of their closed businesses.
Court orders
The District Court ordered the individual and the relevant businesses to do the following:
- Cease the unfair trade practices
- Publish details of the court orders on their online marketing platforms and in major newspapers in Singapore
- Inform potential customers about the court orders prior to contracting with them
- Notify the CCCS of any changes to the business structures and the individual’s employment, control or ownership of the businesses
Failure to comply with the court’s order may result in the individuals and the relevant businesses being found in contempt of court.
Key takeaways
This case demonstrates the CCCS’ strict enforcement stance against individuals who use new business entities to evade detection of unfair trade practices.
This case follows other recent CCCS enforcement actions against businesses for unfair trade practices (see our previous client alerts from August 2025 and July 2025 for more details), and we expect this regulatory scrutiny and strict enforcement to continue. This case is a timely reminder for businesses to ensure their marketing practices remain transparent and compliant with the CPFTA.
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