24/06/24

SINGAPORE: Singapore Identifies Digital Payment Tokens as High-Risk in Anti-Money Laundering Efforts

As published on: msn.com, Monday 24 June, 2024. 

Singapore‘s latest update to its Money Laundering National Risk Assessment (MLNRA) brings to light significant risks and vulnerabilities within the nation’s financial landscape, particularly those posed by digital payment token (DPT) service providers. The comprehensive 126-page report identifies new sectors that were not highlighted in the previous assessment from 2014, underscoring the evolving nature of financial crimes and the challenges they present.

Expanding the Scope of Risk:

  • Digital Payment Tokens: DPT service providers, commonly known as virtual asset service providers, have emerged as a high-risk category. The report notes a noticeable increase in money laundering cases involving digital assets and various methods of exploitation.
  • Precious Stone and Metal Dealers: This sector, newly identified in the report, also presents significant vulnerabilities in the anti-money laundering (AML) landscape.
  • Banking Sector: Despite the focus on new sectors, the banking industry, including wealth management, remains at the forefront of money laundering risks. The sector’s inherent role in handling large volumes of transactions and serving high-risk clients makes it particularly susceptible to criminal exploitation.

High-Risk Financial Sectors:

  • Payment Institutions: Institutions offering cross-border money transfer services are flagged as another high-risk area. These services can be exploited for illicit fund transfers across jurisdictions.
  • External Asset Managers: These entities are also highlighted as vulnerable to money laundering activities due to their role in managing substantial financial assets.

Specific Money Laundering Threats

Primary Threats Identified:


  • Fraud: The report indicates that fraud, especially cyber-enabled fraud, poses one of the most significant threats to Singapore’s financial integrity.
  • Organized Crime and Corruption: These are noted as ongoing risks, with organized crime groups and corrupt practices frequently using sophisticated methods to launder money.
  • Tax Crimes and Trade-Based Money Laundering: These continue to be major concerns, with illicit funds being disguised through complex trade and tax evasion schemes.

Common Money Laundering Methods:

  • Use of Singapore Bank Accounts: Criminals often hide illegal funds in domestic bank accounts, leveraging Singapore’s robust banking infrastructure.
  • Fake Companies: The creation of fictitious businesses to launder money remains a prevalent tactic.
  • Investment in High-Value Assets: Illicit funds are frequently converted into valuable assets such as real estate or precious metals, providing a relatively stable means of preserving wealth.

Despite Singapore’s relatively modest share of global DPT activities, the authorities remain vigilant about the associated risks. The MLNRA report reflects a proactive stance in addressing these issues, combining insights from various supervisory and law enforcement agencies, including the Financial Intelligence Unit. Feedback from private sector entities and foreign authorities further enriches the assessment.


Regulatory Responses:

  • Enhanced Supervision: Singapore’s Financial Intelligence Unit and other agencies continuously monitor and analyze the financial sector for emerging threats.
  • Public-Private Collaboration: The report underscores the importance of collaboration between government bodies and private sector entities in combating money laundering.

Singapore’s Financial Hub Status
Singapore’s reputation as an international financial center and its open economy make it an attractive target for money laundering. Criminals exploit the nation’s advanced financial and business infrastructure to launder or transfer illicit funds.

Vulnerabilities in Financial Infrastructure:

  • Conversion of Illicit Funds: The transformation of illegal proceeds into assets like digital payment tokens, real estate, or precious metals presents a significant risk.
  • Complex Financial Transactions: Singapore’s sophisticated financial system can be misused for layering illicit funds through multiple transactions to obscure their origins.

Legislative Developments

In response to the evolving risks, the Monetary Authority of Singapore (MAS) announced in April plans to amend the Payment Services Act. These amendments aim to expand the regulatory scope concerning services provided by digital payment token providers, ensuring a more robust framework to mitigate money laundering risks.

Proposed Amendments:

  • Extended Regulatory Oversight: The amendments will broaden the range of regulated services, enhancing control over DPT-related activities.
  • Strengthened Compliance Requirements: Digital payment token service providers will be subject to more stringent compliance and monitoring standards.


Singapore’s updated MLNRA highlights the dynamic and evolving landscape of money laundering risks. As digital payment tokens and other new financial technologies continue to develop, so too do the methods used by criminals to exploit these innovations. The comprehensive approach taken in the MLNRA report demonstrates Singapore’s commitment to maintaining its financial integrity and preventing money laundering.

The combined efforts of regulatory authorities, law enforcement, and the private sector are crucial in addressing these challenges. With the impending legislative changes and ongoing vigilance, Singapore aims to reinforce its position as a secure and trustworthy global financial hub.

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Singapore Anti-Money Laundering Digital Payment Tokens

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