• Key initiatives coming out of Singapore in the last few years suggest they are a country taking the fight against financial crime and ML as a serious matter that has the attention of Singapores political leadership, not least as a result of 1MDB and the more recent Singapore $3billion ML case and having a Singaporean in T Rajar Kumar as President of FATF from 2022 – 2024 who included as priorities across FATF the need to do more on asset recovery in particular.

• Singapore announced in October, 2024, its National Anti-Money Laundering (AML) Strategy, which introduced new methods to detect, prevent, and punish ML activities, all while emphasizing the need for collaboration across society and beyond Singapore’s borders. Lessons were learned from both IMDB and the S$3 Billion case, both which cost the State some brownie points as to its reputation, but root cause analysis and lessons learned only makes you stronger and additional scrutiny and measures for Banks, Real Estate Agents, Company Service Providers is the result.

• Continuing the work of ACIP – the PPP established in 2017 which continues to provide a public and private collaboration and information sharing at a strategic level. See: HERE 

• The establishment and go live of COSMIC, a tactical operational and scaleable pilot PPP (P2P via PPP) where actual high quality investigative information is passed amongst COSMIC participants (Banks and FIU/MAS), which arose in part out of the learnings from the 1MDB case. See:HERE  

• The focus on fraud scams and anti fraud and scam measures including establishing the Anti Scam Command in the Singapore Police Force and creating the Anti Scam Centre in 2019 which also includes representatives from the main local Banks co located to help prevent fraud and scams by freezing at speed suspected fraud and scam attempts against Singaporeans. The work of Aileen Yap and her team and the extended private support is quite remarkable, as is the outreach around the world to show and tell what’s possible and what the future looks like – not just in combatting fraud and scams. See:HERE

• Despite this and many other initiatives, including ground breaking action by local leading Banks, figures for reported scams in Singapore rose significantly to record highs to S$1.1 Billion (US$820 Billion) in 2014 up 70% on 2023. See: HERE . A recent FT article described Singaporeans as “rich and naive” which could have been described more kindly but the fact they are relatively very wealthy, speak languages common to many overseas, and have a trust in authority that has been hard earned and now used against them through manipulation is a piece of the problem. See: HERE

• Almost 49,000 SARs were filed in 2022, with 58% from Banks, 15% from each of Casinos and Exchange Houses, an increase from almost 46,000 in 2021 up from 34,000 in 2020. The Suspicious Transaction Reporting Office (STRO), Singapore’s Financial Intelligence Unit (FIU), plans to provide feedback on Suspicious Activity Reports (SARs) to the top 10 reporters, which is something long asked for by filers which should further increase the relevance quality and usefulness of SARs as well as enabling reporters to adjust their systems and better train their systems. See: HERE 

• The substantial increase in asset recoveries, not least as a result of the investigation prosecution conviction and asset seizures related to the S$3 billion case which arose in 2023 and as at the end of 2024 authorities confirmed that S$2.79 Billion had been surrendered to the State, of which S$1.54 was in cash or financial assets and the rest in non cash assets such as cars properties and luxury items. See: HERE

• Between 2019 and 2024 Singapore reported it has seized S$6 billion ($4.4 billion) linked to criminal and money laundering activities, of which about half of these illicit assets were from last year’s record S$ case, & averaging at US$880 Million a year. See: HERE

• With a GDP of US$500 billion and proceeds of crime estimated at between 2-5%, Singapore with its low crime rate and its capacity to respond is likely closer to 2%. Taking 2% of GDP as an estimate of proceeds of crime (US$10 Billion), US$880 Million in asset recoveries represents 8% of estimated POC for Singapore, which is much higher than the global average at less than 1% and with only a few including Italy & UAE around or above 5%.

• ML investigations and convictions data are hard to come by. We may have to wait for the release of the FATF report for that. Whilst those involved in the S$3 Billion case were also found guilty of ML, the convictions were light in terms of time to be spent in jail, largely because the underlying predicate offence, generally assumed to be from illegal gambling was hard to prove and connections with the proceeds of crime and assets in Singapore was a challenge.

• In 2024 the Terrorism Finance Risk Assessment was updated and published. It took into account key developments since the last TF NRA in 2020, such as the evolving global and regional terrorism landscape, growth of the digital economy and financial services in Asia, and emerging TF risk typologies. Similar to 2020, the 2024 TF NRA has observed that the TF threat of raising and moving funds for terrorists and terrorism activities overseas remains pertinent in Singapore’s context. Self-radicalised individuals continue to pose the most salient TF threat to Singapore. 

• Also in 2024 the Virtual Asset Risk Assessment was published. It found that, Singapore, a FinTech hub where digital financial services are easily accessible, is vulnerable to the threats brought about by virtual assets. Statistics and cases from law enforcement agencies, and data from industry players reveal that the common threats include cyber enabled fraud, cybercrime through ransomware and thefts from wallets, and money laundering using DPTs. These are largely similar to the typologies observed in other jurisdictions and featured in reports1 on the money laundering (ML) and virtual asset-related risks. Other threats noted from international typologies and observations include illegal online gambling, drug offences and corruption. The authorities are also vigilant to the potential abuse of virtual assets and their service providers for proliferation financing (PF) and terrorist financing (TF), though we have not observed this risk materialising in Singapore as yet.

• Again in 2024 Singapore published its Proliferation Finance Risk Assessment which reported that Singapore faced the key proliferation financing threats of misuse of legal persons, shipto-ship transfers, movement of dual-use goods, export of luxury goods and misuse of virtual assets. Having identified Singapore’s key proliferation financing threats, the sectors with greater exposure to these threats, for the financial sectors, were: banks, digital payment token service providers, remittance agents and maritime insurers; for the non-financial sectors, corporate service providers, precious stones and precious metals dealers, and lawyers. 

Assessing countries is a complex task, and whilst it’s the FATFs assessors responsibility, combating ML should be done to reduce financial crime,  the proceeds of crime, the harms and costs and to protect a country from the all these negative consequences. The fact that FATF is in town is helpful but Singaporeans expect their government and all those that can support to be on this 24/7 – 365 days of the year otherwise it’s unlikely effectiveness even if temporary can be sustained.

Effectiveness of the response is always going to be a relative consideration so with threats going up in Singapore and elsewhere is the nature and scale of the response which is substantial still enough, despite it looking a lot better than most!?

Again for a copy of the FCN Singapore Financial Crime Dashboard published in June 2025, see HERE: FCN Singapore Dashboard June25Pbd

For a previous Singapore Dashboard published in 2022 See: HERE