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Decoding Money Laundering: Singapore’s Response to Billion Dollar Money Laundering Scheme (Final)

Legal Framework and Implications for Charities


Singapore, a global financial hub, has recently been thrust into the spotlight due to one of the largest money laundering schemes in the world. This case involves nine men and one woman, originally from China, who are accused of money laundering and forgery of official documents submitted to monetary and financial institutions. The accused allegedly made donations to local charities and social service agencies, raising concerns about the legal ramifications for these charities. In this legal analysis, we will delve into the legal framework surrounding this case, Singapore’s response, and the potential implications for charitable organizations.

Money Laundering and Forged Documents

The accused in this case are facing charges of money laundering, a serious financial crime that involves the process of making illegally obtained money appear legitimate. Money laundering typically involves several stages, including the placement of illicit funds into the financial system, layering to conceal the source of funds, and integration to make the funds appear legitimate. The use of forged documents to substantiate the sources of funds in bank accounts is a critical element of this money laundering operation.

Singapore’s Response

The Singaporean authorities first detected irregularities in 2021 when they noticed possibly forged documents being used to justify the sources of funds in bank accounts. To avoid alerting the suspected money launderers, a small group of police officers initially conducted investigations. Subsequently, an extensive probe in 2022 uncovered a network of individuals allegedly transferring money to Singapore from abroad, suspected to be proceeds of criminal activities. These activities include illegal online gambling, online gaming, and unlicensed moneylending.

As part of their response, Singaporean financial institutions and other companies filed Suspicious Transaction Reports (STRs) when they observed suspicious activities. STRs serve as signals for the Suspicious Transaction Reporting Office to initiate further investigations. Importantly, filing an STR does not imply conclusive evidence of criminal conduct. Instead, it triggers a review to determine if the donor or source of funding warrants further scrutiny.

The Legal Framework

Singapore has a robust legal framework in place to combat money laundering and financial crimes. The primary legislation governing anti-money laundering (AML) and countering the financing of terrorism (CFT) in Singapore is the Corruption, Drug Trafficking, and Other Serious Crimes (Confiscation of Benefits) Act (CDSA). Under the CDSA, various measures are established to detect, deter, and prevent money laundering, including the obligation for financial institutions to conduct customer due diligence and file STRs.

Charities that accept donations from dubious sources can face significant legal penalties in Singapore. If it is determined that a charity has used donations originating from illicit sources, the authorities may take action, which can include freezing the charity’s assets or confiscating the tainted funds. This places a significant onus on charities to ensure the legitimacy of their donors and the funds they receive.

Charities and Suspicious Transactions

Mrs. Josephine Teo, Second Minister for Home Affairs, emphasized the importance of charities promptly filing STRs if they find irregularities in their donor records. It is crucial for charities to demonstrate that they have taken reasonable precautions, conducted necessary anti-money laundering checks, and acted in good faith when accepting donations. Such charities may be treated more leniently in the event of an investigation.

Implications for Charities

Charities have a responsibility to conduct due diligence on their donors and the sources of funds they receive. Failure to do so can lead to serious legal consequences, including the freezing of assets or confiscation of funds. The recent advisory issued by the Commissioner of Charities underscores the need for charities to review their donor records, particularly in cases where donations may have originated from the accused or entities linked to them.

In light of this case, charities in Singapore should take proactive measures to enhance their AML and CFT procedures. This includes implementing robust Know Your Customer (KYC) checks, verifying the legitimacy of donors, and conducting ongoing monitoring of donor transactions. Charities must also be prepared to file STRs when irregularities are detected.

Review of Singapore’s Legal Framework

In response to this high-profile money laundering case, Singapore has announced a review of its legal framework concerning financial crimes. The government aims to ensure that its laws are up to date and effective in combating money laundering and related offenses. The Monetary Authority of Singapore (MAS) has emphasized the importance of robust due diligence checks by financial institutions when dealing with entities that may be linked to illicit activities.


The multi-billion-dollar money laundering scheme in Singapore has brought significant attention to the country’s legal framework and its implications for charities. Money laundering remains a grave concern in the global financial landscape, and Singapore’s response reflects its commitment to combat such illicit activities. Charities must be diligent in their efforts to verify the legitimacy of donors and funds they receive, as non-compliance can have severe legal consequences. As Singapore reviews its legal framework, it aims to strengthen its ability to address money laundering effectively and protect its reputation as a global financial centre.


Please note that this article does not constitute express or implied legal advice, whether in whole or in part. For a Consultation or if you simply require more information, email us at


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