Singapore Publishes Updated Money Laundering National Risk Assessment

    Singapore published today its updated Money Laundering (ML) National Risk Assessment (NRA), as part of Singapore’s continuing efforts to maintain the effectiveness of its anti-money laundering (AML) regime amidst the evolving risk landscape. The updated ML NRA synthesises the ML risks observed by the Singapore supervisory and law enforcement agencies, and Singapore’s Financial Intelligence Unit – the Suspicious Transaction Reporting Office (STRO), as well as feedback from private sector entities and counterpart foreign authorities. Since its last ML NRA in 2014, Singapore has been closely monitoring our ML risks including conducting thematic risks assessments in relation to abuse of legal persons, virtual assets, and environmental crime ML, to ensure that these risks are surfaced in a timely manner to facilitate targeted risk mitigation across relevant stakeholders. 

2   Singapore’s position as an international financial centre and as a trading and transit hub with a highly externally oriented economy exposes it to the risks of criminals exploiting our economic openness, financial system and business infrastructure to launder or move illicit funds and assets. Singapore also faces risks as a location for criminals to convert their illicit funds to other assets, such as real estate or precious stones and precious metals. Shifts in the economic and geopolitical landscape have increased these risks, while the increased use of technology has enabled rapid and large transactions across borders, often involving the use of sophisticated money laundering structures and arrangements.  

3   The updated ML NRA highlights that: 

•   Singapore’s key ML threats stem from fraud, particularly foreign and domestic cyber-enabled fraud, orchestrated by criminal syndicates typically located overseas. Other key ML threats relate to foreign predicate crimes such as organised crime, corruption, tax crimes, and trade-based money laundering.  

•   Consistent with international typologies, the most common ML typologies include: (i) illicit funds flowing into or through Singapore via bank accounts; (ii) misuse of legal persons such as shell companies to channel illicit funds; and (iii) placement of illicit funds in high value assets such as real estate and precious stones and metals. 

•   The banking (including wealth management) sector is assessed to pose the highest ML risks to Singapore. Banks have higher exposure to ML threats and are more easily exploited by criminals due to their role in facilitating large volumes of transactions in the financial system and servicing customers with higher ML risks, including those from jurisdictions with higher ML risks. 

•   Among the Designated Non-Financial Businesses and Professions (DNFBP) sectors, corporate service providers (CSPs) pose higher ML risks given the role CSPs play in providing upstream services such as incorporation of companies, and that they are linked to the misuse of legal persons in some instances. Other DNFBP sectors which pose higher risks include real estate, licensed trust companies¹, casinos and precious stones and metals sectors. 

•   Within the financial sectors, a higher risk sector of note would be the digital payment token (DPT) services providers (or virtual assets service providers). There has been an increase in reported cases involving DPTs and there is a range of ways in which DPTs can be exploited. Hence, while DPT activities in Singapore form a small portion of global activities, Singapore authorities are closely monitoring the risks involving the sector. Other sectors within the financial industry posing higher ML risks are payment institutions providing cross-border money transfer services (including remittance agents), and external asset managers.  

4   Singapore remains committed to reviewing and putting in place appropriate measures to address the identified risks.  The findings in the updated ML NRA will guide our ongoing efforts to ensure that our AML regime keeps pace with the identified risks. These include continued risk-targeted efforts to sensitise Financial Institutions (FIs) and DNFBPs to the key, new and emerging ML risks, as well as to allow more timely detection, disruption and enforcement of illicit activities by law enforcement and supervisory agencies. 

5   The findings from the updated ML NRA, together with other risk assessments conducted by the authorities, serve as a guide for all stakeholders, including FIs and DNFBPs, to continue to strengthen the implementation of risk-based measures in Singapore’s fight against ML. FI and DNFBP sectors should take reference from the updated ML NRA in assessing their risks and enhance their controls accordingly. Please refer to a copy of the ML NRA here.

Issued by:
Ministry of Home Affairs
Ministry of Finance
Monetary Authority of Singapore

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[1] Licensed Trust Companies are regulated as a part of the financial sector.