In more detail

The IMC has collaborated with relevant stakeholders, including industry bodies, regulatory agencies and law enforcement, to calibrate recommendations to strengthen Singapore's AML framework.

The three key pillars of Singapore's AML framework are prevention, detection and enforcement.

• Proactive prevention: This pillar aims to build on existing frameworks to proactively prevent criminals from laundering illicit proceeds, including strengthening AML standards for gatekeepers (e.g., financial institutions and corporate service providers) and supporting their efforts to combat money laundering.

Additionally, one of the recommendations under the Prevention pillar was to engage, educate and raise awareness on money laundering risks among non-regulated sectors, such as unregulated high-value goods dealers. Such education efforts aim to highlight how dealers can mitigate AML risks (for instance, not accepting cash payment for large sums) and how to file a Suspicious Transaction Report.

• Timely detection: The IMC will enable sector supervisors and gatekeepers to make timely detection of illicit activities. This includes strengthening information and data sharing among and between gatekeepers and the government. In particular, the IMC will develop a new whole-of-government data sharing interface, the National AML Verification Interface for Government Agencies Threat Evaluation (NAVIGATE), through which various agencies can seamlessly screen against shared databases to assess AML risks.

Effective enforcement: Recommendations under this pillar include enhancing legislative powers for law enforcement agencies to prosecute AML offences, enhancing penalty frameworks for AML offenses, and strengthening inter-agency cooperation for enforcement efforts.

The government has already begun to implement these recommendations, some of which were effected by the recent Anti-Money Laundering and Other Matters Act 2024. You may refer to our client alert here for more details.

Key takeaways

The IMC's recommendations reflect Singapore's commitment to actively combat money laundering and uphold its reputation as a trusted financial system and business hub.

All organizations, whether regulated or not, are responsible for their efforts in the detection of money laundering.

Under Section 45 of the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992, anyone who knows or has reasonable grounds to suspect that any property may be connected to criminal conduct through the course of their trade, profession, business or employment must file a Suspicious Transaction Report as soon as is reasonably practicable. Any individual who fails to do so may face a fine of up to SGD 250,000 and/or imprisonment of up to three years, and any organization that fails to do so may face a fine of up to SGD 500,000.

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