Update On Enforcement Actions In The Legal Sector Arising From The 2023 Case
1 August 2025 Posted in Press releases
1. On 15 July 2025, the Ministry of Law (“MinLaw”) issued a press release on ongoing inquiries and enforcement actions by the Director of Legal Services (“DLS”) against a number of law practices involved in the conveyancing of the real estate properties seized in an anti-money laundering operation in August 2023. The DLS had then concluded inquiries into 11 out of 24 law practices, taken action against four of the law practices and referred a lawyer to the Law Society of Singapore for disciplinary action[1].
2. The DLS has now made further referrals of lawyers related to the four law practices to the Law Society, to consider if there are grounds for further professional disciplinary action against these lawyers. With this, the DLS has completed the regulatory action related to the four law practices, and can provide more details of these cases.
3. In addition, as at 31 July 2025, the DLS has also completed inquiries into, and regulatory action against, another two law practices. As such, the DLS has dealt with 13 out of the 24 law practices.
4. Inquiries into the remaining 11 law practices are ongoing.
Enforcement actions
5. The enforcement actions on the relevant law practices and follow-up actions on lawyers are detailed below:
(1) Anthony Law Corporation (“ALC”)
The DLS has ordered ALC to pay a financial penalty of $100,000. A lawyer from ALC, Mr Tan Chau Chuang, has been referred to the Law Society.
ALC had acted for nine clients to convey 25 properties valued at around $135 million in total. ALC’s breaches included inadequate scrutiny of the transactions which was not commensurate with the clients’ and transactions’ money-laundering risks. ALC did not corroborate or verify the clients’ explanations for why the transactions were being funded by seemingly unrelated third parties, even though these were red flags. ALC also failed to comply with documentation requirements. It had retained and continued to undertake transactions for some of these clients despite filing Suspicious Transaction Reports (“STRs”) against them, and did not substantiate or document its reasons for why it had considered appropriate to do so.
ALC has paid the financial penalty.
(2) Fortis Law Corporation (“FLC”)
The DLS has ordered FLC to pay a financial penalty of $30,000 and referred two lawyers, Mr Andrew Wong Wei Kiat (who is no longer practising at FLC) and Mr Tan Tse Chia Patrick, to the Law Society.
FLC had acted for 16 clients to convey 55 properties valued at around $398.7 million in total. FLC did not conduct checks to verify the clients’ claims that the payments for the transactions were indeed from legitimate remittance companies.
FLC has paid the financial penalty.
(3) Legal Solutions LLC (“LS”)
The DLS has ordered LS to pay a financial penalty of $70,000 and referred a lawyer, Mr Ee Tian Huat Patrick (who is no longer practising at LS) to the Law Society.
LS had acted for two clients to convey 20 properties valued at around $117 million in total. It did not adequately document the details of its analysis of the clients’ money-laundering risks. It also did not perform all the required enhanced customer due diligence measures after it filed a STR, such as documenting its internal discussions on, and reasons for, retaining the clients despite filing the STR.
(4) Malkin & Maxwell LLP (“M&M”)
The DLS has reprimanded M&M to remind it to be mindful of its anti-money laundering obligations and responsibilities.
This took into consideration that M&M had acted for one client to convey one property valued at around $40 million. The inquiries revealed that while M&M conducted checks into the client’s source of funds, its independent checks were not sufficiently in-depth. Instead, it relied unduly on checks which it assumed that third parties would have done on its client.
(5) William Poh & Louis Lim (“WPLL”), now Louis Lim & Partners; and
(6) Templars Law LLC (“TL”)
Mr Poh Tian Hock William was the managing partner and sole partner-in-charge of conveyancing matters at WPLL until around May 2023. During that time, he had commenced transactions for six clients to convey 32 properties valued at around $246.7 million in total. 26 of these property transactions concluded while Mr Poh was practising in WPLL.
Mr Poh subsequently left WPLL on or around May 2023 to join TL. WPLL amended its name to “Louis Lim & Partners” after Mr Poh’s departure. Mr Poh brought the remaining six property transactions to TL and concluded the transactions soon after in June 2023.
Breaches which the DLS had observed include not obtaining certain documents as part of customer due diligence, not adequately scrutinising the clients’ and transactions’ money-laundering risks, and not applying commensurate risk mitigation measures.
Having considered the facts of the case, the DLS has reprimanded both law practices to remind them to be mindful of their anti-money laundering obligations and responsibilities, and referred Mr Poh to the Law Society.
6. In the cases described above, the fees that each law practice had collected in total from acting for their clients for these transactions ranged from $15,000 to around $170,000.
7. In imposing the financial penalties, alongside other regulatory measures that include following up with these law practices on their remedial measures to strengthen compliance with anti-money laundering obligations, the DLS aims to ensure that law practices in Singapore observe their anti-money laundering obligations and keep Singapore a clean and money-laundering-free business- and financial-hub.
Remaining cases
8. Inquiries into the remaining 11 law practices are ongoing and more information will be provided after the DLS completes these remaining inquiries and enforcement actions.
Legal sector anti-money laundering obligations
9. All law practices and lawyers are subject to anti-money laundering obligations under the Legal Profession Act 1966. These obligations are reviewed and updated from time-to-time – most recently on 1 July 2025 when the Legal Profession (Prevention of Money Laundering, Financing of Terrorism and Proliferation Financing) Rules 2015[2] was amended – for robustness and consistency with applicable international standards.
Law practices are regulated by DLS
10. The DLS is appointed under the Legal Profession Act as the regulator for all licensed law practices in Singapore. A law practice that breaches its anti-money laundering obligations is liable, amongst other things, to face regulatory control action against its licence by the DLS. The DLS takes into consideration all relevant factors when determining the appropriate enforcement actions and any further regulatory follow-ups with the law practices. These factors include (but are not limited to):
(i) The law practice’s compliance with its entity-level anti-money laundering obligations;
(ii) Any remediation measures which the law practice might propose to strengthen its anti-money laundering compliance; and
(iii) The roles of the individual lawyers who were involved in the case (including whether it appears to the DLS that the lawyer has potentially breached his or her anti-money laundering obligations).
The Law Society and disciplinary action against lawyers
11. A lawyer who breaches his or her anti-money laundering obligations is liable, amongst other things, to face disciplinary proceedings. Under the Legal Profession Act, all disciplinary complaints against a lawyer are submitted to the Law Society of Singapore, who administers the overall processing of these complaints.
12. Lawyers whom the DLS has referred to the Law Society will be subject to the disciplinary proceedings process and framework in the Legal Profession Act. Under this framework, each lawyer’s case will undergo further fact-finding by the relevant committee or tribunal to assess if there have been breaches, and if so, the lawyer’s individual culpability and any appropriate disciplinary action and penalties against him/her. This disciplinary process is separate from the DLS’ inquiries and enforcement actions against the law practices. We urge the public to refrain from speculating or sharing unverified information while the process is ongoing.
13. All law practices and lawyers must be mindful of their anti-money laundering obligations under the Legal Profession Act.
MINISTRY OF LAW
1 AUGUST 2025
[1] The DLS had also determined that it will not be necessary to take further regulatory action against the other 7 law practices. See press release issued by MinLaw on 15 July 2025.
[2] Previously named the “Legal Profession (Prevention of Money Laundering and Financing of Terrorism) Rules 2015” until 30 June 2025.
Last updated on 1 August 2025