Background

On 15 July 2025, the Ministry of Law (MinLaw) and the Director of Legal Services (DLS) released an update on enforcement actions against law practices involved in conveyancing transactions linked to the August 2023 major money laundering case. The update highlights regulatory breaches and reiterates AML/CFT obligations under the Legal Profession Act.

Key Enforcements

MinLaw’s review covered 24 law practices, of which only 11 have been concluded, and the following enforcement actions have been put in place by the DLS to four of the law practices and one lawyer:

• Ordered two law practices to pay financial penalties of $30,000 and $100,000 respectively.
• 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.
• Privately reprimanded a fourth law practice.
• Referred one lawyer to the Law Society of Singapore for disciplinary action.
• Determined that it will not be necessary to take further regulatory action against 7 law practices.

Regulatory Expectations

MinLaw emphasised that:

• Law practices must perform proper risk-based assessments for each client, conduct CDD, and file STRs promptly.
• Where firms continue to act for high-risk clients, they must substantiate and document mitigating actions.
• Internal AML frameworks must be in place, regularly updated, and adhered to.
• Lawyers are individually accountable for ensuring compliance with AML obligations.

What’s Next?

• Investigations into the remaining 13 firms are ongoing, with further enforcement actions expected.
• Firms should refer to the guidance note issued by MinLaw on 23 June 2025 for best practices and compliance standards.
• The legal sector is expected to significantly enhance AML controls, particularly in conveyancing practices.

How Can We Help?

Capital Governance assists law practices by:

• Reviewing and auditing AML/CFT operations, including CDD forensics.
• Enhancing internal controls and delivering AML training aligned with MinLaw expectations…and more.

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