by Jonathan J. Rusch

Since 2023, when Singapore Police arrested 10 people connected with Singapore’s largest-ever case of money laundering (involving S$3 billion in cash and assets)[1], the Monetary Authority of Singapore (MAS) has been conducting supervisory examinations against pertinent financial institutions with a nexus to persons of interest in that case and certain employees of those financial institutions.

On July 4, the MAS announced regulatory actions against nine financial institutions and prohibition orders and reprimands against 18 executives and managers of those institutions for failure to comply with MAS’s Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) requirements.[2]  This post will summarize those actions and identify certain lessons to be learned for AML/CFT compliance.

Regulatory Actions Against Financial Institutions

The MAS imposed a total of S$27.45 million in financial penalties against a total of nine financial institutions.  Those institutions included a number of Singapore branches of leading global banks, as well as two capital market services license holders and one licensed trust company.  The penalties took into account various factors, including the extent of the financial institutions’ exposure to the persons of interest, the number of breaches of MAS’ requirements, and the degree of weakness in the financial institutions’ AML/CFT controls.

Although the MAS observed that overall, most of the financial institutions had established AML/CFT policies and controls, it made clear that the AML/CFT breaches arose out of poor or inconsistent implementation of these policies and controls.  In particular, the MAS found shortcomings in four areas:

• Customer risk assessment: Five of the financial institutions “failed to implement adequate policies or processes for the rating of ML risks presented by some of their customers.” That led to misrating of money laundering risks and affected their ability to apply appropriate controls to and address higher money laundering risks presented by several persons of interest.
• Establishing and corroborating source of wealth of customers who posed a higher risk of money laundering: All nine financial institutions “did not detect or adequately follow up on significant discrepancies or red flags noted in information and documents that should have cast doubt on some customers’ purported [sources of wealth] and which indicated increased risk of [money laundering]. In some cases, there was no corroboration of significant aspects of [source of wealth].”
• Transaction monitoring: Eight financial institutions “failed to adequately review relevant transactions flagged as suspicious by their own systems. The relevant transactions were unusually large, inconsistent with the customers’ profiles, or showed unusual patterns.”
• Post-Suspicious Transaction Report (STR) Followup: In relation to customers on whom the financial institutions had filed STRs, two of those financial institutions “failed to take adequate and timely risk mitigation measures, such as enhanced monitoring and reviewing their risk classification.”[3]

Regulatory Actions Against Individuals

The MAS issued prohibition orders, ranging from three to six years’ duration, to four executives and managers connected with one of the sanctioned institutions, Blue Ocean Invest Pte. Ltd. (BOIPL).[4]  The MAS stated that the Chief Executive Officer and the Chief Financial Officer (1) “failed as senior managers to ensure that the AML/CFT policies and controls in BOIPL kept pace with significant growth in its business in the three years since the company was set up”; (2) “failed to develop and implement adequate policies and controls in multiple areas, such as [source of wealth] corroboration, customer risk assessment, customer name screening and ongoing reviews of customer due diligence (CDD) information”; and (3) “failed to ensure that BOIPL’s AML/CFT policies and controls were subjected to audit reviews.”  All four BOIPL executives and managers “also failed to raise red flags when they were aware of information that should raise suspicion and failed to perform enhanced CDD for multiple [persons of interest].”[5]

The MAS also issued reprimands to five other individuals for multiple AML/CFT lapses. It cited three executives of the licensed trust company, Trident Trust Company (Singapore) Pte. Limited (TTCSPL), for failure to ensure TTCSPL’s compliance with MAS’s requirements.  In particular, it cited two of the executives, as senior managers of TTCSPL, for failure to ensure that TTCSPL’s policies provided sufficient practical guidance on how to establish customers’ sources of wealth and cited all three executives for failure, as members of TTCSPL’s New Business Committee, to detect or adequately assess multiple deficiencies in customers’ source of wealth corroboration when approving the onboarding of higher risk customers.

The MAS further reprimanded two other individuals – both former Team Heads of Group Retail Privilege Banking at United Overseas Bank Limited (UOB) — for failures to conduct or ensure proper due diligence or post-STR follow-up in respect of several persons of interest. Finally, it privately reprimanded another nine Relationship Managers (RM) and RM supervisors for more limited lapses.

Lessons to Be Learned

The MAS stated in its announcement of these actions that it has published supervisory expectations regarding the controls that financial institutions should implement to address the key findings from its supervisory examinations related to this case. It also stated that the banking industry “has also published best practice papers on implementing these controls, particularly in the area of source of wealth corroboration”, and that financial institutions “should benchmark themselves against MAS’ supervisory expectations and industry best practices, and execute robust, reasonable and risk-proportionate defences against [money laundering].”[6]

The MAS further reminded RMs and their supervisors that they are part of the first line of defense in [financial institutions] against ML/TF risks. They should exercise the necessary vigilance and be alert to material red flags when dealing with existing and prospective customers, including when reviewing information obtained from such customers as part of the CDD process. They should identify and escalate concerns internally where warranted, so that appropriate risk mitigation measures can be taken.[7]

The monetary penalties in this case – none of which exceeded S$5.8 million — may appear modest compared with the nine- and ten-figure penalties that the Financial Crimes Enforcement Network and other U.S. agencies have sometimes meted out for significant AML/CFT violations.[8]  Even so, the combination of penalties, prohibition orders, and reprimands that mentioned specific institutions and individuals by name should remind financial institutions doing business in Singapore, whether local or global, that they need to maintain constant vigilance in not only designing their AML/CFT programs well, but implementing those programs to function effectively on a continuing basis.[9]

Jonathan J. Rusch is Director of the U.S. and International Anti-Corruption Law Program and Adjunct Professor at American University Washington College of Law and a Senior Fellow with the NYU Program on Corporate Compliance and Enforcement at New York University Law School.

The views, opinions and positions expressed within all posts are those of the author(s) alone and do not represent those of the Program on Corporate Compliance and Enforcement (PCCE) or of the New York University School of Law. PCCE makes no representations as to the accuracy, completeness and validity or any statements made on this site and will not be liable any errors, omissions or representations. The copyright of this content belongs to the author(s) and any liability with regards to infringement of intellectual property rights remains with the author(s).

Footnotes

[1]   See David Sun, Roman Sverdan, and Laura Aragó, Vast and tangled web: S’pore’s largest case of money laundering, Singapore Straits-Times, updated July 8, 2024, https://www.straitstimes.com/multimedia/graphics/2023/12/money-laundering-universe-who-is-who/index.html.

[2]   See Monetary Authority of Singapore, MAS Takes Regulatory Actions against 9 Financial Institutions for AML-Related Breaches, July 4, 2025, https://www.mas.gov.sg/regulation/enforcement/enforcement-actions/2025/mas-takes-regulatory-actions-against-9-financial-institutions-for-aml-related-breaches.

[3]   Id.

[4]   The prohibition orders bar each individual from (1) carrying on any activity or business, or providing any service, the carrying on or provision of which is regulated or authorized by MAS, and from taking part, directly or indirectly, in the management of, or acting as a director, partner or manager of, any financial institution; (2) becoming a substantial shareholder of any financial institution that is a corporation; and (3) if they are already a substantial shareholder of a financial institution that is a corporation, from acquiring any interest in any voting share in the financial institution other than a voting share in which they already have an interest.  In addition, the Chief Executive Officer and the Chief Financial Officer are prohibited from performing the function of risk management and control.  Id.

[5]   Id.

[6]   Id.

[7]   Id.

[8]   See, e.g., Financial Crimes Enforcement Network, Financial Crimes Enforcement Network (FinCEN) Year in Review for Fiscal Year 2024 at 8 (2025), https://www.fincen.gov/sites/default/files/shared/FinCEN-Infographic-Public-2025-508.pdf.

[9]   See, e.g., Monetary Authority of Singapore, Guidelines to MAS Notice 626  on Prevention of Mo0ney Laundering and Countering  the Financing of Terrorism §1-4-12 at 3 (revised October 18, 2024), https://www.mas.gov.sg/-/media/mas-media-library/regulation/guidelines/amld/guidelines-to-notice-626-on-prevention-of-money-laundering-and-cft-for-banks/guidelines-to-mas-notice-626-revised-18-oct-2024–red-line-version.pdf; Criminal Division, U.S. Department of Justice, Evaluation of Corporate Compliance Programs 10 (updated September 2024), https://www.justice.gov/criminal/criminal-fraud/page/file/937501/dl?inline=.