Background

On 4 July 2025, the Monetary Authority of Singapore (MAS) concluded its enforcement actions against nine financial institutions and several individuals following supervisory examinations related to the major money laundering case uncovered in August 2023. These institutions were found to have significant links to persons of interest involved in the case.

Key Regulatory Actions

Financial Institutions

• MAS imposed S$27.45 million in composition penalties on nine financial institutions, including banks, capital markets intermediaries, and a licensed trust company. The amount of each penalty reflected the level of exposure to the persons of interest, number of breaches, and the severity of weaknesses in AML/CFT controls.
• Key findings identified:
  1. Inadequate customer risk assessments;
  2. Failure to establish and corroborate the source of wealth for higher-risk customers;
  3. Insufficient review of transactions flagged as suspicious by internal systems;
  4. Lack of timely follow-up actions after filing suspicious transaction reports.

The composition penalties are as follows:

FI	Composition Penalty
Banks
Credit Suisse Singapore Branch (CSSB)	S$5.8million
United Overseas Bank Limited (UOB)	S$5.6million
UBS AG, Singapore Branch (UBSS)	S$3 million
Citibank N.A. Singapore (CNAS) and Citibank Singapore Limited (CSL), collectively “Citi”	S$2.6 million
Bank Julius Baer & Co. Ltd., Singapore Branch (BJBS)	S$2.4 million
LGT Bank (Singapore) Ltd. (LGTS)	S$1 million
Capital Market Services Licence Holders
UOB Kay Hian Private Limited (UOBKH) under Fund Management company license (FMC)	S$2.85 million
Blue Ocean Invest Pte. Ltd. (BOIPL) under Fund Management company license (FMC)	S$2.4 million
Licensed Trust Company
Trident Trust Company (Singapore) Pte. Limited (TTCSPL)	S$1.8 million

• All penalised institutions have commenced remediation plans, which will be subject to ongoing monitoring by MAS.

Individuals

• MAS also took regulatory actions against individuals:

• • Prohibition Orders, ranging from three to six years, were issued to four former senior personnel and relationship managers from Blue Ocean Invest Pte. Ltd.
  • Public reprimands were issued to senior management staff at Trident Trust Company (Singapore) Pte. Limited and United Overseas Bank Limited for deficiencies in oversight and compliance.
  • Nine additional individuals received private reprimands for limited lapses.

 

General Observations

MAS also noted that although most financial institutions had established AML/CFT frameworks, many of the breaches stemmed from poor or inconsistent implementation.

What’s Next?

• MAS has published supervisory expectations on strengthening anti-money laundering controls, especially in areas such as source of wealth verification and follow-up procedures.
• Financial Institutions are expected to benchmark themselves against the supervisory expectations and several other industry best practices.

How Can We Help?

Capital Governance supports financial institutions by:

• Reviewing AML/CFT frameworks to identify gaps in customer risk assessment, source of wealth verification, and transaction monitoring procedures.
• Advising on remediation plans aligned with MAS’ supervisory expectations and enforcement learnings.
• Delivering targeted training for compliance teams, senior management, and front-line staff to improve detection, escalation, and post-reporting follow-up processes in AML/CFT operations

And more…

Contact Us today to discuss how we can provide the risk and compliance advisory solutions for you. Find out more here.  

To learn more about navigating regulatory expectations and upgrading your AML/CFT operations, contact us for admission to our upcoming special Seminar and Workshop aimed at guiding the C-Suite of financial institution.