Ongoing Enforcement Actions in the Legal Sector Arising from the 2023 Major Money Laundering Case
15 July 2025 Posted in Press releases
1. The Director of Legal Services (“DLS”), supported by the Ministry of Law (“MinLaw”), is conducting inquiries into the law practices that were involved in the conveyancing of the real estate properties seized in an anti-money laundering operation in August 2023.
Legal sector anti-money laundering obligations
2. All law practices and lawyers are subject to anti-money laundering obligations under the Legal Profession Act 1966.
3. These obligations include:
a) performing an adequate analysis of the risks of money laundering in relation to each client;
b) performing customer due diligence (“CDD”) measures that are commensurate with that client’s risk profile;
c) filing a Suspicious Transaction Report with the police if the law practice or lawyer has reasonable grounds to suspect that the client may be engaged in money laundering;
d) if the law practice or lawyer decides to continue to act for the client despite these suspicions – substantiating and documenting the reasons for the decision, and adopting commensurate risk mitigation measures including enhanced CDD and monitoring measures; and
e) for law practices – having internal anti-money laundering policies, procedures and controls which fulfil the regulatory requirements and are sufficiently robust.
4. A law practice that breaches its anti-money laundering obligations is liable, amongst other things, to face regulatory control action against its licence.
5. A lawyer who breaches his or her anti-money laundering obligations is liable, amongst other things, to face disciplinary proceedings, which could result in monetary penalties, suspension from legal practice or disbarment.
Enforcement actions
6. The DLS has conducted investigations into 24 law practices which were involved in providing legal services for the purchase of the real estate properties in question. Thus far, investigations against 11 law practices have been concluded:
a) The DLS has ordered two law practices to pay financial penalties of $30,000 and $100,000 respectively.
b) The DLS has issued a third law practice with a statutory notice of the intention to order that law practice to pay a financial penalty of $70,000. A final decision will be made upon receiving and considering the law practice’s written representations, if any.
c) The DLS has privately reprimanded a fourth law practice.
d) The DLS has also referred one lawyer to the Law Society of Singapore for disciplinary action.
e) The DLS has determined that it will not be necessary to take further regulatory action against 7 law practices.
7. The DLS is considering the inquiry findings for the remaining 13 law practices, and whether any lawyers concerned should be referred to the Law Society of Singapore for disciplinary action.
Continued vigilance against money laundering
8. All law practices and lawyers are reminded of their anti-money laundering obligations under the Legal Profession Act. They may refer to the Law Society’s website on anti-money laundering for more resources.
9. MinLaw also issued a guidance note to the legal industry on 23 June 2025 to further detail the responsibilities of law practices and lawyers under their statutory anti-money laundering obligations. This guidance covers areas such as analysing client risk, identifying material red flags, establishing a client’s source of wealth, the ongoing monitoring of clients and their transactions, and the timelines for filing Suspicious Transaction Reports.
10. Singapore has a comprehensive anti-money laundering regime. However, the landscape is constantly changing, as new money laundering risks and typologies emerge. Everyone has a role in ensuring that Singapore’s anti-money laundering systems continue to be robust, from the law enforcement agencies, to the service providers such as the financial institutions and law practices, to the general public. Members of the public should also be mindful of Singapore’s anti-money laundering laws such as the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992.
MINISTRY OF LAW
15 JULY 2025
Last updated on 15 July 2025