September 26, 2023

The raid and the capture of hundreds of millions of assets and luxury goods has been headline news for a while in Singapore and it raises many questions in the press, for instance on the diligence of the government in granting licences to foreigners to acquire landed property…
Another question that comes to mind is how effective Customer Due Diligence is done on buyers of real estate. Yes, there is a regulation in place but are the over 30 thousand (mostly independent) real estate agents in Singapore properly equipped to perform good CDD?! And do the real estate agent organisations adequately perform quality assurance on the CDD files? What’s the quality of SoF and SoW declarations in Customer Due Diligence? Maybe it’s time for some proper training to real estate agents and thorough QA on CDD in all real estate transactions… As we all know only issuing regulations will not lead to operational compliance.

However, the capture has pushed some other news to the background. To name just a few topics, there’s the jail sentence in the wirecard fraud  , the top level corruption case 
and the questions that were raised in parliament on rental of bungalows by several ministers
Listing these articles that were published in a relatively short period, gives the feeling there’s a lot happening in terms of (suspected) financial crime in Singapore. It’s no longer only about regulations and intentions but we actually see cases coming to the surface and perpetrators being caught. And that’s what the market and everybody out there was looking for. With so much money flowing in and into Singapore the sentiment was and is that ‘it can’t be that nobody gets caught’ .
We can only expect that the regulations and strong stance of the MAS will lead to more exposure of financial crimes and we can only applaud that. At the same time MAS continues its guiding role with the recent issuance of a circular on effective sanctions screening and proper assessment of related risks – an issue that is rightly still top of mind in many countries and organisations the world over.