The Inter-Ministerial Committee (IMC) released its report today to share the findings and recommendations following a review of Singapore’s Anti-Money Laundering (AML) framework. The overarching strategy is a whole-of-society approach, in which relevant stakeholders, who are part of our frontline of defence, need to work collaboratively with the Government.

2. The IMC review, drawing lessons from the major money laundering (ML) case in August 2023, was convened to ensure that our system remains relevant against increasingly sophisticated criminal tactics. It focused on five key areas:

a) How to better prevent money launderers from misusing corporate structures;

b) How financial institutions can enhance their controls and collaborate more effectively with one another and the authorities to guard against and flag suspicious transactions;

c) 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 ML risks, including the adequacy of the existing regulatory framework over these players;

d) How to better centralise and strengthen monitoring and sense-making capabilities across government agencies to detect suspicious activities; and

e) How to strengthen enforcement levers and capabilities to enable firm and decisive actions against money launderers, including depriving them of ill-gotten proceeds. 

 Recommendations

3. The IMC’s recommendations enhance Singapore’s framework to combat money laundering whilst remaining welcoming of the large majority of businesses, which are law-abiding and legitimate.

4. The IMC’s recommendations and accompanying measures will strengthen the three key prongs underpinning Singapore’s AML framework – “Proactive Prevention, Timely Detection, Effective Enforcement”. The IMC has also reviewed existing and in-progress measures, in identifying the following recommendations:

a) Proactive Prevention: Building on existing AML frameworks to proactively prevent criminals from laundering their illicit proceeds, by:

i. Strengthening AML standards for gatekeepers

ii. Further supporting gatekeepers in enhancing their capabilities to combat ML

iii. Engaging non-regulated sectors to enhance their understanding of ML risks

iv. Strengthening mechanisms to deter the misuse of companies 

b) Timely Detection: Enabling sector supervisors and gatekeepers in the timely detection of illicit activities, through:

i. Strengthening sensemaking and information-sharing within government

ii. Deepening channels for data sharing amongst and with gatekeepers

c) Effective Enforcement: Taking effective enforcement actions against criminals who engage in illicit activities, by:

i. Enhancing legislative levers for law enforcement agencies to better pursue and prosecute ML offences

ii. Continuously reviewing penalty frameworks to ensure that they remain proportionate and dissuasive

iii. Strengthening inter-agency coordination to enable swifter and more effective action against illicit ML activities

5. The IMC’s recommendations are Singapore’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. Singapore will continue to enhance our defences by adopting risk-proportionate measures to detect and deter criminals, safeguard our institutions and systems, while ensuring that we remain welcoming to legitimate investors and businesses. 

6. The IMC’s full report is available below.

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