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SG is money-laundering hub

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How $2.8b money laundering probe affects S’pore’s economy, property and charities​

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Su Haijin, one of the 10 accused in the money laundering probe, being apprehended at 16 Ewart Park on Aug 15. PHOTO: ST READER
Andrew Wong

OCT 3, 2023

SINGAPORE – Ministers and MPs engaged in a nearly four-hour-long exchange on Tuesday on an ongoing $2.8 billion money laundering probe, the largest in Singapore.
After the three ministerial statements were delivered in Parliament, members of the House spoke at length on how to ensure best practices and compliance with the country’s anti-money laundering stance.
Here are some highlights:
Workers’ Party MP He Ting Ru (Sengkang GRC) asked how Singapore’s economy, specifically its wealth and asset management industries, would be affected as investigations unravel the extent of the money laundering.
Minister of State for Trade and Industry Alvin Tan said the flow of funds into Singapore is testament to the robustness and dynamism of its financial sector. The sector contributes 14 per cent of the country’s GDP and provides some 200,000 jobs.
“We must and we will continue to build our financial sectors, which means good jobs for Singaporeans and enhances our standing as an international financial centre,” he added.
Mr Tan said that while illicit funds may slip through the system, the majority of the transactions in Singapore remain legitimate.

“So it’s very important we don’t throw the baby out with the bathwater; we throw only the dirty water out. That’s really important.”
This can be achieved as Singapore has a robust anti-money laundering and counter-terrorism financing framework that is in line with international standards, he added.
Mr Yip Hon Weng (Yio Chu Kang) asked if current checks on property transactions are sufficient, and how compliance with standards is ensured.

Second Minister for Finance Indranee Rajah said property developers and agents have an obligation to file suspicious transaction reports (STRs). They act as gatekeepers against money laundering for the industry, she added.
Said Ms Indranee: “The key thing that real estate agents and others in the non-financial sectors have to do is to spot when something seems off, something is inconsistent, something cannot be explained.”
She added that while it is impossible to ensure Singapore will never be targeted by criminals due to its status as a financial hub, mitigating steps can be taken.
The Republic can turn itself into an inhospitable place for criminals through prevention, detection and enforcement measures, she noted.

Mr Edward Chia (Holland-Bukit Timah GRC) asked for steps charities can take to safeguard against illicit funds and donations.
Mr Tan said charity organisations have a legal obligation to file STRs. “Charities should exercise vigilance when accepting donations, in particular, when the donors are unknown or unfamiliar to the charities,” he pointed out.
Some of the 10 people accused in the probe were reported to have made donations to local charities.
Mr Tan said more precautions should be taken when substantial amounts are donated by people unknown or unfamiliar to the organisations. Reasonable due diligence to check on the legitimacy of the source of funds or donations should also be done by the charity, he added.

Workers’ Party chairwoman Sylvia Lim asked how the probe started and if the Chinese authorities have been assisting with investigations. Second Minister for Home Affairs Josephine Teo said the probe began from a variety of gatekeepers, including banks, corporate service providers and real estate agents. She added: “As to whether we connected the dots using only STRs, the answer is no.
“There will also be exchange of information with foreign counterparts... There will be other sources of intelligence.”
As investigations are ongoing, she cannot reveal with which foreign law enforcement agencies Singapore is working.
“Suffice to say, there will be a variety because the proceeds that potentially have been laundered through the Singapore system involve activities that were carried outside of Singapore,” she added.
 

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Detecting money laundering like looking for ‘one needle in several haystacks’: Josephine Teo​

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Second Minister for Home Affairs Josephine Teo said it is the responsibility of gatekeepers to do the necessary checks and flag risks. PHOTO: GOV.SG
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David Sun
Crime Correspondent

Oct 3, 2023

SINGAPORE – Detecting illicit activity is challenging because of the many transactions Singapore handles daily as a leading international financial centre, said Second Minister for Home Affairs Josephine Teo on Tuesday.
It is the responsibility of gatekeepers – from financial institutions and corporate service providers to property agents and dealers of precious stones and metals – to do the necessary checks and flag risks, as many do, she added.
She was delivering a ministerial statement on Singapore’s anti-money laundering regime in Parliament, addressing questions from MPs about a recent money laundering case involving over $2.8 billion in cash and assets.
It is Singapore’s worst money laundering case so far.
Mrs Teo said: “As one of the leading international financial centres in the world, the daily transactions in Singapore are voluminous.
“The reality is that this sheer volume provides easy camouflage for illicit activities. Spotting a suspicious transaction among millions is challenging.
“It’s not just one needle in a haystack, but one needle in several haystacks,” she added.

So far, for that case, 10 people have been arrested and charged. Mrs Teo said there may be more arrests and seizing of assets. Several other people, including family members of those arrested, are assisting with investigations, and at least eight people are on the run.
Mrs Teo said Singapore has an anti-money laundering regime that involves collaboration across the different government ministries and agencies, and also with financial institutions and international agencies.
She said: “When we (are) open for business – and we must be – criminals will also try to exploit the same economic openness and our strong reputation for the rule of law, to launder their illicit funds, and create the appearance of legitimacy.

“In fact, all major financial hubs, not just Singapore, are vulnerable. The same characteristics that make them attractive as financial hubs also make them attractive targets for money laundering.”
Even with strict measures, it is inevitable that dirty money will still find its way to Singapore’s shores, she said. “We are under no illusion that we can always keep out dirty money,” said Mrs Teo.
She added that Singapore has to respond decisively when such activities are uncovered.

The first prong of Singapore’s anti-money laundering strategy is prevention, which involves gatekeepers in various sectors, and includes financial institutions, real estate agents, lawyers, accountants, and dealers of precious stones and metals. These gatekeepers are legally required to conduct due diligence, looking out for red flags and filing reports when they come across suspicious transactions.
For example, dealers of precious stones and metals must file cash transaction reports with the Suspicious Transaction Reporting Office (STRO) of the Commercial Affairs Department if they conduct transactions involving cash of more than $20,000.
Mrs Teo revealed that since 2021, 96 enforcement actions have been taken against dealers for failure to comply with customer due diligence and cash transaction reporting requirements.
For the recent money laundering case, The Straits Times reported in September that the Ministry of Law had sent out a notice to dealers of precious metals and stones with the names of 34 individuals who could be linked to suspicious transactions. The list included the names of the 10 accused and their family members.
The dealers were told to review transactions and business relations, and to file a report if they came across suspicious transactions involving the names on the list.

Mrs Teo added that in this money laundering case, several suspects had bought high-value assets like luxury cars, bags, liquor and ornaments that are not regulated.
She said the authorities will be looking to see if Singapore needs to extend anti-money laundering requirements to new classes of assets.
The second prong of detection relies largely on the STRO and reports filed. The STRO works with different sectors and regulators to develop a list of red flag indicators that is regularly updated to tackle emerging risk types and trends.
The office received about 43,000 reports annually between 2020 and 2022 – an average of about 150 reports every working day. Of these, 80 per cent were filed by financial institutions.
Mrs Teo said intelligence received by the STRO is extensively analysed and shared with relevant government agencies.
However, the bad actors are always looking to outdo the authorities, she added.
“All this work done by STRO, sectoral regulators and police is incredibly difficult,” she said. “It’s also not a static field, because determined money launderers are always finding new ways to hide their tracks and avoid detection.”

The third prong of Singapore’s anti-money laundering strategy is enforcement.
Mrs Teo said that from 2020 to 2022, at least 240 people have been convicted of money laundering offences. More than $1.2 billion worth of assets were seized by the police during this period, and most of the money came from scam proceeds.
She said Singapore has a robust anti-money laundering regime, and it is held in high regard internationally.
She cited how Singapore had rendered assistance to British law enforcement agencies for a case involving former Formula One boss Bernie Ecclestone.
In that case, the Monetary Authority of Singapore, police and Attorney-General’s Chambers worked closely with the British authorities on their investigation, proactively sharing information with their British counterparts to help them develop their case.
Mrs Teo concluded her statement by saying that the recent money laundering case showed that Singapore’s anti-money laundering regime works.
“This case is a reminder that even the most stringent preventive measures can be circumvented by determined criminals,” she said.
“But it also shows that our system is able to detect suspicious individuals and activities, and that when we do, we have the resolve and capabilities to track them down, and take them to task.”

Money laundering cases in Singapore​

1MDB​

  • More than $240 million in assets seized or prohibited here.
  • Three bankers convicted for failure to report suspicious transactions, fined between $10,000 and $128,000 in 2017.
  • One banker convicted of money laundering, jailed for more than four years in 2017.
  • 11 people issued prohibition orders ranging from three years to lifetime bans from working in Singapore’s financial sector for their gross misconduct.

Wirecard​

  • Three banks and an insurer in Singapore issued penalties amounting to $3.8 million for failure to perform customer due diligence.
  • Seven people charged here.
  • Three convicted of offences including money laundering.

Overseas cases​

Bitfinex hack​

Illicit deals in Hong Kong​

  • In January 2023, Hong Kong Customs arrested nine people suspected of 7,600 illicit deals involving over HK$6 billion (S$1 billion).
  • They had operated multiple bank accounts for illegal transactions.

Australian syndicate​

  • In February 2023, the Australian Federal Police charged nine members of an international money laundering syndicate.
  • More than A$150 million (S$130 million) in assets seized.
  • The syndicate had enabled multiple transnational organised crime groups to launder funds derived from criminal activities.
 

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Interpol Red Notices not issued for 10 charged in money laundering case at point of EP application​

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The 10 accused are (clockwise from top left) Su Baolin, Su Haijin, Chen Qingyuan, Su Wenqiang, Lin Baoying, Zhang Ruijin, Wang Dehai, Su Jianfeng, Vang Shuiming and Wang Baosen. ST ILLUSTRATIONS: CEL GULAPA
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Tay Hong Yi

OCT 4, 2023

SINGAPORE – Interpol Red Notices were not issued against all 10 individuals arrested and charged in Singapore’s largest money laundering case at the time when they applied for Employment Passes (EP) or Dependant’s Passes here.
Singapore screens applicants for its work passes and other immigration facilities against a database of blacklisted individuals, and also works with foreign governments to verify information provided by them when agencies here have suspicions, Second Minister for Home Affairs Josephine Teo said in Parliament on Tuesday.
A Red Notice is a request to law enforcement worldwide to locate and provisionally arrest a person pending extradition, surrender, or similar legal action.
She was responding to questions from MPs from both sides of the House on how applications for work passes and other immigration facilities are scrutinised and how checks on high-risk individuals are stepped up. These include those with criminal records or who are wanted in foreign jurisdictions, or who may have used false identities.
Among the MPs who filed questions on immigration and work passes were Mr Don Wee (Chua Chu Kang GRC) and Mr Patrick Tay (Pioneer), as well as Associate Professor Jamus Lim (Sengkang GRC) from the Workers’ Party and Non-Constituency MP Leong Mun Wai from the Progress Singapore Party.

Ms Teo said that while it is not possible to conduct verification checks for all applications due to the high volume, the Government will review how to tighten these checks at various points.
This comes after the Republic moved in August on a money laundering case involving the 10 work pass holders and more than $2.8 billion in laundered assets here.

In her statement, Ms Teo said anyone complicit in the wrongdoing after ongoing investigations on the case will be dealt with in accordance with the law regardless of their immigration status, including Singaporeans.
Foreigners convicted of an offence in Singapore may be deported from Singapore, and in some cases, banned permanently, she said.
“Investigations are ongoing, and many persons have been interviewed, and more will be. They include Singaporeans, permanent residents, and those on different types of immigration passes.”

Even as the Republic reviews how to tighten its verification checks, most people are not illegal money launderers or criminals, Ms Teo said.
“If we make the rules too tight, then it is the vast majority of innocent applicants who will be unnecessarily penalised. The crooks will still try to find a way around the rules.
“So we need rules, (and) we need to apply them, but let us be careful about knee-jerk reactions, which may make our business environment unfriendly.”

Speaking in Parliament on Tuesday, Minister for Manpower Tan See Leng said that the majority of work pass holders come to work and contribute to Singapore’s economy, and only a small minority are unscrupulous individuals.
“We therefore must take a sensible approach to calibrating our checks so that we do not hurt bona fide employers.”
In response to questions from labour MP Desmond Choo (Tampines GRC), Dr Tan elaborated on the checks the ministry undertakes as part of wider Government efforts to combat money laundering.
The Manpower Ministry (MOM) checks whether false declarations of salaries and qualifications have been made, and whether companies have business operations that can cover the declared salaries.
Dr Tan said the EP applications of those involved in the money laundering case were approved as they met prevailing work pass requirements on salary and qualifications.
“When asked for the proof of business operations and the ability to pay salaries, the companies which submitted the applications were able to provide supporting documents.”
The ministry uses data analytics to identify higher-risk work pass applications for greater scrutiny.
“Where there is any sign of possible salary fraud, companies are required to show documentary proof of business operations and their abilities to pay salaries.”

Firms can still ask for more proof even after the work pass holder arrives in Singapore or when passes are up for renewal, Dr Tan said.
But some individuals may still abuse Singapore’s work pass framework to enter the country and commit illicit activities, such as in the present case of money laundering.
“Some may pretend to be employed by companies that are actually inactive or dormant, but others may operate companies with an active trading front to mask the movement of their ill-gotten gains, and yet others still may own a portfolio of legitimate and illicit businesses,” Dr Tan said.
Noting that criminals will constantly find new methods to make detection even harder, Dr Tan said MOM’s salary fraud checks should be seen as a first layer of checks within a larger system of checks by the Government to guard against money laundering.
He added that MOM will be part of the inter-ministerial committee to strengthen Singapore’s anti-money laundering regime.
Better sharing of information across agencies would help MOM improve its salary fraud checks, Dr Tan said, adding that the ministry will share salary fraud cases with other agencies to conduct further probes.
 

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Singapore Tries to Plug Money-Laundering Loopholes

Singapore’s money laundering case surpasses US$2 billion​

Oct 4

By: Toh Han Shih​

Singapore authorities are trying to strengthen vulnerabilities in the Asian financial hub’s anti-money laundering (AML) system as the value of assets seized or frozen in one of the biggest money laundering cases in the city’s history nearly tripled to over S$2.8 billion (US$2 billion) from less than two months ago.
“This case is one of the largest anti-money laundering operations not just in Singapore but the world,” Second Home Affairs Minister Josephine Teo said in parliament on October 3.
The value of assets seized 152 properties and 62 vehicles with a total value of more than S$1.24 billion and bank accounts of more than S$1.45 billion, Teo revealed. “There may be more arrests and assets seized,” she warned.
In comparison, when Singapore police first announced their crackdown on August 16, the value of assets seized and frozen was S$1 billion including over S$110 million in bank accounts. On August 15, police arrested nine men and one woman, all originating from Fujian province in China, according to the police announcement.
“We must and we will do more. The fact that more than S$1.45 billion in financial assets have so far been seized in relation to this case is concerning,” said Minister of State for Trade and Industry Alvin Tan told parliament.
The Monetary Authority of Singapore (MAS) is conducting detailed reviews and inspections of the financial institutions (FIs) with a major nexus to this case, Tan said. “MAS will also take a critical look at how the suspects were able to access financial services in Singapore. Some of them have been charged for presenting forged documents to FIs,” said Tan, who is a board member of MAS.
MAS will assess whether FIs had upheld robust anti-money laundering/counter-terrorist financing (AML/CFT) practices, including performing adequate checks on their customers’ sources of wealth and funds, and monitoring customer transactions to pick out suspicious ones, he added. The agency is reviewing its processes on single family offices (SFOs) and will tighten them where necessary, Tan disclosed. “Ongoing investigations and supervisory engagements suggest that one or more of the accused persons in this case may have been linked to SFOs that were awarded tax incentives.”
An inter-ministerial committee, led by Second Minister of Finance Indranee Rajah, will be formed to consider further measures, Teo said. “We will consider further measures to strengthen our regime.”
“Where gaps are identified, we will tighten our regulations and enforcement to prevent exploitation by criminals,” said Rajah in parliament on October 3. The committee will focus on four main areas, Rajah explained.
The first focus is on how Singapore can better prevent corporate structures from being abused by money launderers, the second is on how financial institutions can enhance their controls and collaborate more effectively with each other, while the third is how corporate service providers, real estate agents, and jewelry dealers can better guard against money laundering risks, Indranee said. “Fourth, how we can centralize and strengthen monitoring and sense-making capabilities across government agencies to better detect suspicious activities.”
According to the Financial Action Task Force (FATF), the global anti-money laundering organization, Singapore is partly compliant with customer due diligence on Designated Non-Financial Businesses and Professions (DNFBPs), which include jewelry retailers, company service providers, and property agents.
“We will examine if Singapore needs to extend anti-money laundering regulations to new classes of assets beyond what FATF has recommended,” said Teo, noting luxury cars are currently not regulated under Singapore’s anti-money laundering regime.
China’s role
“There has been speculation circulating in news outlets internationally and domestically that this operation was carried out at the behest of China. This is completely untrue,” said Teo.
“Singapore does not need another country to tell us what to do to enforce our laws.” She revealed out that police began investigating this case two years ago in 2021.
In parliament on October 3, Sylvia Lim, chairman of the opposition Workers’ Party, noted some of the suspects were reportedly wanted by Chinese police for alleged involvement in organized crime. Lim asked whether Chinese authorities were assisting in the Singapore investigation.
Teo replied that she was not at liberty to disclose the foreign law enforcement agencies cooperating with Singapore. “Suffice to say that there would be a variety because the proceeds that potentially have been laundered through the Singapore system involve activities that were carried outside of Singapore. They could involve more than one jurisdiction. As we cast our net wide, it would not be unusual or unthinkable for us to be cooperating with other law enforcement agencies, not confined to one country China.”
Foreign cooperation
Teo cited two cases which involved the Singapore authorities working with foreign authorities to trace and interdict illicit proceeds in Singapore. In February 2021, she said, police received information from international partners and commenced investigations into the embezzlement of Angolan state funds that were alleged to have been laundered in foreign banks in Singapore. In the course of the investigations, she said, police seized over S$750 million from several bank accounts in Singapore.
In another example, she said, authorities have rendered assistance to UK law enforcement agencies for a case involving former Formula One boss Bernie Ecclestone, with authorities proactively sharing information with UK counterparts which helped them develop their case on Ecclestone. Ecclestone played a key role in bringing the Formula One race to Singapore. He is due to appear in a UK court in November to face charges for not declaring more than £400 million held in a trust in Singapore to the British government. Another key figure involved with Formula One in Singapore is the country’s transport minister and minister-in-charge of trade relations, S Iswaran, who is under investigation for corruption. It is not known if Iswaran is connected to Ecclestone’s case.
Toh Han Shih is chief analyst of Headland Intelligence, a Hong Kong risk consultancy
 

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RWS fined $95,000 for failing to perform customer due diligence measures​

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RWS was fined $200,000 in total for failing to perform customer due diligence measures the previous financial year. PHOTO: ST FILE
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Samuel Devaraj

SEP 27, 2023

SINGAPORE – Resorts World Sentosa (RWS) was fined a total of $95,000 in the last financial year for breaching casino control regulations by not doing proper checks on its customers.
Between April 2022 and March 2023, the integrated resort was fined $20,000 for failing to perform customer due diligence measures, and $75,000 for failing to perform enhanced customer due diligence measures, said the Gambling Regulatory Authority (GRA).
In its annual report published online on Tuesday, GRA said it had also suspended the licence of Ceylon Sports Club for one month.
This was over the club’s failure to comply with regulatory requirements relating to the screening and registration of people and prevention of entry of excluded people.
GRA, a statutory board under the Ministry of Home Affairs, was inaugurated on Aug 16, 2022.
It replaces the Casino Regulatory Authority (CRA), which was established in 2008 to oversee Singapore’s two integrated resorts, RWS and Marina Bay Sands (MBS).
In the previous financial year, RWS was fined $200,000 in total by CRA for failing to perform customer due diligence measures.

It was also fined $75,000 for failing to implement a system of internal controls approved by an authority.
The highest amount of fines handed out by CRA over the last 10 years was between April 2018 and March 2019.
During that period, RWS was hit with $730,000 in fines, and MBS had to cough up $15,000 for various breaches.
The Straits Times has reached out to GRA for more details on the breaches by RWS. The resort declined to comment when contacted by ST on Wednesday.
 

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Money laundering case: Some suspects donated six-figure sums to charities​

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Some of the charities have ringfenced the money, while others lodged police reports and plan to surrender the cash to the police. PHOTOS: LIANHE ZAOBAO FILE, ST FILE
Andrew Wong and Samuel Devaraj

Oct 8, 2023

SINGAPORE - At least five of the 10 accused in the $2.8 billion money laundering case have allegedly donated to various charitable organisations and social service agencies in the past three years.
This includes at least $52,000 to Rainbow Centre, the operator of three special education schools, and at least $15,000 to the National Kidney Foundation (NKF), checks by The Sunday Times showed.
Lions Befrienders, a social service agency that serves the elderly, said it received $5,000 from one of the men in 2022.
In Parliament on Tuesday, Second Minister for Home Affairs Josephine Teo said in her ministerial statement that some of those arrested had made donations to charities here.
Some of the charities have ring-fenced the money, while others lodged police reports and plan to surrender the cash to the police.
ST asked 10 charities and non-profit organisations if they had received donations from any of the 10 accused in the case.
According to Rainbow Centre’s annual report, it received between $30,000 and $99,999 from a Wang Shuiming in 2022.

Turkish national Vang Shuiming, 42, who is also known as Wang Shuiming, faces five charges: one for using a forged document and four for money laundering.
The documents from Rainbow Centre also show that a Su Haijin had donated between $3,000 and $9,999 each year between 2021 and 2023, while a Zhang Ruijin donated between $10,000 and $29,999 in 2021, and between $3,000 and $9,999 in 2022.
Cypriot national Su Haijin, 40, faces one charge of money laundering and another for resisting arrest.

Chinese national Zhang Ruijin, 44, faces a total of three forgery charges.
A Su Baolin appeared in NKF’s annual reports from 2020 to 2022, in a list of people who donated at least $5,000 annually to the organisation.
Cambodian national Su Baolin, 41, faces two forgery charges.
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The 10 accused are (clockwise from top left) Su Baolin, Su Haijin, Chen Qingyuan, Su Wenqiang, Lin Baoying, Zhang Ruijin, Wang Dehai, Su Jianfeng, Vang Shuiming and Wang Baosen. ST ILLUSTRATIONS: CEL GULAPA
An NKF spokeswoman said the charity could not confirm if it was the same Su Baolin involved in the case, and did not say if it was aware of any donations made by anyone linked to the money laundering case.
She said NKF has a policy of due diligence checks on its donations, to provide beneficiaries with “reasonable assurance” that the donation did not come from any illegal source.
“In instances where there are concerns about the ethical implications of a potential or suspicious donation, a decision will be made to decline the donation following the due diligence check,” she said, adding that the relevant authorities would be notified, if necessary.
Rainbow Centre did not reply by press time.
Lions Befrienders executive director Karen Wee said it received a $5,000 donation in 2022 from one of the 10, but declined to reveal the person’s name.
Ms Wee said: “Even though the amount of money was small compared to the $2.1 million we raised in 2022-2023, we made a police report because Lions Befrienders is about transparency and accountability.
“We will return the money if we have to.”

On Aug 15, more than 400 officers led by the Commercial Affairs Department raided locations including Tanglin, Bukit Timah, Orchard Road, Sentosa and River Valley.
Nine men and one woman, originally from China, were charged the next day with offences including money laundering, forgery and resisting arrest.
It is Singapore’s worst money laundering case and one of the world’s largest.
There were earlier media reports of Sian Chay Medical Institution receiving donations from some of the accused.
On Aug 24, the social service agency told ST the amounts included a cheque of $100,000 each from Su Haijin, Su Baolin and Zhang Ruijin in 2020, which were then given to the President’s Challenge.
Sian Chay’s spokesman added that from 2020 to 2022, Su Haijin donated an additional $101,000 in total to the organisation.
Su Baolin donated an additional $39,000 from 2021 to 2023 in total, while Zhang Ruijin donated an additional $12,000 in 2021.
On Aug 30, Zhang Ruijin’s defence lawyer, in arguing for his client to be granted bail, said in court he had been active in doing charity work, and had donated to local charities.
On Tuesday, Mrs Teo said the Commissioner of Charities will be issuing an advisory to encourage all charities to review donor records to check if they have received donations from the 10 accused or entities that are related to them.
Charities that find irregularities must file suspicious transaction reports (STRs), she added.

Under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act, individuals or organisations must file an STR if they know or reasonably suspect that a property – in this case, a cash donation – may be linked to serious crimes, including money laundering.
An individual who fails to do so may be fined up to $250,000 or jailed for up to three years, while an organisation can be fined up to $500,000.
Ms Victoria Ting, associate director at Setia Law, said whether a charity organisation can be taken to task depends on whether it should have reasonably suspected the source of donations could be tainted.
The former deputy public prosecutor, who specialised in white-collar crime, said red flags include a mismatch between the donor and donation.
She said: “For example, when a donation in the name of a company is wired from a personal account, or an unusually large donation is received which does not seem commensurate with the donor’s known background or income.”
Another red flag, she said, is when a large donation is “smurfed” – a tactic money launderers use to split up transfers into multiple smaller amounts, which suggests an intention to avoid triggering reporting requirements.
But the task could be daunting for charities that may not be equipped to handle such checks.

Lions Befriender’s Ms Wee said: “We have multiple sources of donations and a large volume of donors, and it is difficult to do in-depth checks on each of them.”
She said that for organisations like hers, typically only large amounts above $10,000 would trigger greater scrutiny.
This includes verification checks to ensure the donation is not from someone blacklisted by the police or who has a dubious background or businesses.
The organisation has limited methods to conduct background checks on potential donors. Ms Wee said checks can be done with the credit bureau, but this will work only if the businesses or individuals are operating in Singapore.
Otherwise, she said, they rely on public announcements or police updates on potential offenders.
“Ultimately, what kinds of checks charities do and which donors we check on is a judgment call that we need to make based on the limited resources we have,” she added.

Meanwhile, Ms Ting said money launderers donate to charities for several reasons.
She said: “Where the charity is legitimate, it could be to lower their taxable income, to obtain goodwill and standing in the community, or even just to acquire good karma.
“On the other hand, where charities can also be entirely controlled by a criminal group, then it could operate as a front to receive and transmit illicit payments akin to any other shell company.”
ST reported on Sept 18 that some Chinese businessmen had tried to offer money in the form of donations, in exchange for honorary titles in clan associations.
Mr Or Teck Seng, general secretary of the Singapore Ann Kway Association, said: “From my understanding, this is to show they are assimilating into society, which is one of the prerequisites of either becoming a Singapore citizen or getting permanent resident status.”
Lawyer Chenthil Kumarasingam, a partner at Withers KhattarWong, said some criminals may use charity organisations to hide their ill-gotten gains.
“Essentially, the idea is to pass the funds through the charity’s bank accounts and then access them later, whether through corruption in the charity or setting up sham charities to accept the funds from a directed donation,” he said.
 

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$2.8b money laundering case: What happens to tainted donations?​

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Charities that accept donations from dubious donors can face significant legal penalties in Singapore. PHOTO: SINGAPORE POLICE FORCE
Andrew Wong and Samuel Devaraj

Oct 8, 2023

SINGAPORE – Charities that accept donations from dubious donors can face significant legal penalties in Singapore, which may involve the freezing of their assets or confiscation of the illegal funds.
Mr Chenthil Kumarasingam, partner at Withers KhattarWong, said this could prove problematic for the charities involved, especially if they were negligent in conducting anti-money laundering checks.
He said: “If a charity is found to have used donations originating from illicit sources, the authorities may seek to recover these funds. It might involve freezing the charity’s assets or seeking a court order to confiscate the tainted funds.”
The authorities might also recover an equivalent amount even if the funds have been used.
“This could potentially impact the charity’s financial health, especially if large sums are involved,” Mr Kumarasingam added.
On Tuesday, Second Minister for Home Affairs Josephine Teo issued a ministerial statement to update the public about the money laundering case that has seen the authorities take over more than $2.8 billion in assets and cash.
She said some of the accused donated to charities here.

In Singapore’s worst money laundering case so far, the police on Aug 15 conducted raids involving more than 400 officers led by the Commercial Affairs Department (CAD).
Nine men and one woman, originally from China, were charged the next day with offences that include money laundering, forgery and resisting arrest.
Checks by The Sunday Times found that some of the accused allegedly donated to local charities and social service agencies.

This includes at least $52,000 to Rainbow Centre, the operator of three special education schools; at least $15,000 to the National Kidney Foundation; and at least $5,000 to Lions Befrienders, a social service agency.
Mrs Teo had said charities that find irregularities must file suspicious transaction reports (STRs).
A police spokesman said STRs are not conclusive of criminal conduct. Rather, they act as a signal for the Suspicious Transaction Reporting Office to determine if the donor or source of funding warrants further investigations.
These checks are conducted by the CAD.

Mr Kumarasingam said filing an STR is pivotal for charities that have received monies from illicit donors.
“If a charity can demonstrate it has taken reasonable precautions, conducted necessary anti-money laundering checks, and acted in good faith, it may be treated more leniently.”
He said if a charity received donations from suspicious donors, the Commissioner of Charities can investigate the charity’s records and accounts.
This means the charity’s officers could face personal liabilities if they had knowingly accepted illicit funds, or if investigations reveal that due diligence had not been conducted to verify the sources of donations.
Mr Kumarasingam said: “Charities implicated in such situations often face reputational damage, which might affect future donations and public trust. Transparency and proactive measures to rectify mistakes are crucial in such scenarios.”
 

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Rainbow Centre to review policies after confirming it received $72k from money laundering accused​

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The donations to Rainbow Centre, an operator of three special needs schools, were made between 2020 and 2023. PHOTO: LIANHE ZAOBAO FILE
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Samuel Devaraj

Oct 8, 2023

SINGAPORE - Rainbow Centre said on Sunday that it received $72,450 from three of the 10 accused in the $2.8 billion money laundering case and that it will be reviewing its policies.
The operator of three special needs schools posted a statement on its website following an article in The Sunday Times about charities receiving money from some of the accused. The article said the centre had received at least $52,000 from the three men.
This information was obtained from the organisation’s annual reports. ST had contacted Rainbow Centre for comment on the donations before publishing the article, but did not receive a response in time.
On Sunday, the centre said that after the names of the suspects were released in August, it began an internal investigation and sought advice from the authorities on the donations, while awaiting an official advisory from the Commissioner of Charities.
It said it had received $30,000 from Turkish national Wang Shuiming. The 42-year-old, who is also known as Vang Shuiming, faces five charges – one for using a forged document and four for money laundering.
It also received $25,350 from Cypriot national Su Haijin, 40, who faces one charge of money laundering and another for resisting arrest, and $17,100 from Chinese national Zhang Ruijin, 44, who faces a total of three forgery charges.
The donations were made between 2020 and 2023.

The centre said it takes its legal obligations seriously and adheres to all applicable laws and regulations related to money laundering prevention.
It added: “We will be reviewing our policies and due diligence processes, and, if necessary, will implement measures to further ensure that at all times, (Rainbow Centre) is in full compliance with all its legal and regulatory obligations.
“Rainbow Centre wishes to assure its beneficiaries and donors that contributions are handled responsibly, and every effort is made to ensure full compliance with the law.”
On Aug 15, more than 400 officers led by the Commercial Affairs Department raided locations including Tanglin, Bukit Timah, Orchard Road, Sentosa and River Valley.
Nine men and one woman, originally from China, were charged the next day with offences including money laundering, forgery and resisting arrest. It is Singapore’s worst money laundering case and one of the world’s largest.
Among the assets worth over $2.8 billion that the authorities have taken control of are 152 properties and 62 vehicles with an estimated value of more than $1.24 billion, money in bank accounts amounting to more than $1.45 billion, and cash of various currencies worth more than $76 million.

In Parliament last Tuesday, Second Minister for Home Affairs Josephine Teo said in her ministerial statement that some of those arrested had made donations to charities here.
Some of the charities have ring-fenced the money, while others lodged police reports and plan to surrender the cash to the police, she added.
Various organisations like Lions Befrienders and Sian Chay Medical Institution confirmed that they had received donations from some of the accused, with the former saying it has filed a police report.
A lawyer told ST that charities which accept donations from dubious donors can face significant legal penalties in Singapore, which may involve freezing of their assets or confiscation of the illegal funds
 

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Singapore banks sharpen scrutiny after $2.8 billion money laundering scandal: Sources​

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The changes in due diligence by banks come after police in August arrested and charged 10 foreigners in Singapore. ST PHOTO: SHINTARO TAY

Oct 9, 2023

SINGAPORE - Banks in Singapore are taking longer than usual to perform due diligence on clients and closing accounts in some cases, sources said, as procedures tighten after the financial hub’s biggest money laundering scandal, which involved $2.8 billion in assets.
Banks such as OCBC, Citigroup and UOB are demanding more documents than usual in some cases to verify sources of wealth, two of the sources said.
Also, wait times for wealthy individuals opening bank accounts have risen significantly from the one to three months typical before the scandal, said the sources who spoke on condition of anonymity as the matter is sensitive.
In a statement, the Monetary Authority of Singapore (MAS) said financial firms must verify customers’ identities, establish the sources of wealth and funds of higher-risk clients, and keep track of transactions.
“These requirements are not new,” MAS said in response to a Reuters request for comment. “Given the attributes and size of their transactions, high-net-worth individuals are often subjected to more stringent checks by financial institutions.”
The changes in due diligence by banks come after police in August arrested and charged 10 foreigners, all from China, a big source of fund inflows, in Singapore’s most dramatic swoop of its kind.
The authorities have seized about $2.8 billion worth of assets, from luxury real estate and cryptocurrencies to gold bars, designer handbags and funds parked in banks such as Credit Suisse and Julius Baer.

One source, a wealth manager with a Singapore bank, said after the scandal that only “high-quality clients with good profiles and substantial assets under management” could expect to get a private banking account opened within three months.
A spokesman for Singapore’s second-biggest lender, OCBC, said the bank devoted “significant” resources to continuously strengthen controls, and worked closely with regulators and peers to guard against illicit activities.
Citi said: “We are committed to the fight against money laundering and ensuring the highest standard of governance and controls.

“We have been working with the authorities to strengthen and protect the integrity of the financial system.”
In a statement, UOB said it was vigilant against risks from money laundering or terrorism financing, and ensured robust checks were part of its due diligence checks, making use of data analytics and technology solutions.
Credit Suisse and Julius Baer declined to comment.

Accounts review
The scandal comes at a time when Singapore is experiencing a sharp jump in asset inflows from China, Hong Kong and elsewhere, drawn by its relative political stability, low taxes, and policies favourable for setting up funds.
Total assets under management in Singapore rose 16 per cent to $5.4 trillion in 2021, the latest central bank figures show, outstripping an increase of 12 per cent worldwide that year, to US$112 trillion (S$153 trillion).
With the scandal prompting questions about Singapore’s image as a wealth hub, the authorities are stepping up inspections into financial firms suspected of involvement in the case.
The increased checks have led some banks to drop clients.
“We have conducted a review of the accounts... and regret that we can no longer support them,” OCBC said in a notice reviewed by Reuters, adding that it was unable to say what factors prompted its decision.
A Chinese national and permanent resident of Singapore said OCBC notified them in September that it would close their decade-old account, without giving a reason.
The individual, who sought anonymity, believed the closure was due to suspicion of money laundering, as the account featured in regular transactions with business partners in China.
OCBC did not comment on this specific case.
A real estate agent, who advises wealthy foreign and domestic individuals, said the opening of bank accounts was now taking much longer than usual for some clients.
“Business is very tough for us now, there are so many hurdles we have to go through,” the agent added. “But better to be extra careful than get involved in crime.” REUTERS
 

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Money laundering case: President’s Challenge received over $350k in donations, ComChest got $30k​

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ComChest and President's Challenge have since filed police reports and suspicious transaction reports. PHOTOS: SINGAPORE POLICE FORCE, FACEBOOK/COMCHEST, PRESIDENT'S CHALLENGE
Samuel Devaraj and Christine Tan

Oct 11, 2023

SINGAPORE - The Community Chest (ComChest) received $30,000 and President’s Challenge got more than $350,000 from individuals whose names are similar to those of individuals charged in the $2.8 billion money laundering case.
Ms Charmaine Leung, managing director of ComChest, the philanthropy and engagement arm of the National Council of Social Service, told The Straits Times this on Wednesday.
She said ComChest has since filed police reports and suspicious transaction reports (STRs).
She said: “Donations that have been disbursed to benefiting agencies will not be affected. We are working closely with the Commissioner of Charities (COC) to determine how to treat the donations.”
ComChest was set up in 1983. It currently supports 100 social agencies and assists almost 100,000 people each year.
Similarly, a President’s Challenge spokesman said it has filed police reports and STRs, and donations already disbursed to benefiting agencies will not be affected.
The spokesman added that it was also working closely with the COC to determine how to treat the donations.

Both organisations did not say who among the 10 charged in the case had donated the money.
In Parliament on Oct 3, Second Minister for Home Affairs Josephine Teo said in her ministerial statement that some of those arrested had donated to charities here.
She said some of the charities have ring-fenced the money, while others lodged police reports and plan to surrender the cash to the police.


ST reported on Sunday that various organisations received money from some of the 10 accused in Singapore’s worst money laundering case and one of the world’s largest.
On Aug 15, more than 400 officers led by the Commercial Affairs Department raided locations including Tanglin, Bukit Timah, Orchard Road, Sentosa and River Valley.
Nine men and one woman, originally from China, were charged the next day with offences including money laundering, forgery and resisting arrest.
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The 10 suspects are (clockwise from top left) Su Baolin, Su Haijin, Chen Qingyuan, Su Wenqiang, Lin Baoying, Zhang Ruijin, Wang Dehai, Su Jianfeng, Vang Shuiming and Wang Baosen. ST ILLUSTRATIONS: CEL GULAPA
Among the assets the authorities have taken control of are 152 properties and 62 vehicles with an estimated value of more than $1.24 billion, money in bank accounts amounting to more than $1.45 billion, and cash of various currencies worth more than $76 million.
On Aug 23, a President’s Challenge spokesman told ST it received three cheques of $100,000 each from three individuals, in 2020, whose names are similar to those charged.
The spokesman said the money had come from Sian Chay Medical Institution, a social service agency, which had been donating to President’s Challenge since 2018.
The spokesman said it had no direct relations with the three donors, and received no further donations from them, adding that donations had been disbursed to its benefitting agencies in June 2021.

On Aug 24, Sian Chay said the cheques given to President’s Challenge came from Cypriot national Su Haijin, 40, Cambodian national Su Baolin, 41, and Chinese national Zhang Ruijin, 44.
Sian Chay’s spokesman added that from 2020 to 2022, Su Haijin donated an additional $101,000 in total to the organisation. He faces one charge of money laundering and another for resisting arrest.
Su Baolin, who faces two forgery charges, donated an additional $39,000 from 2021 to 2023 in total.
Zhang Ruijin donated an additional $12,000 in 2021 and faces three forgery charges.
ST’s report on Sunday said Lions Befrienders received a $5,000 donation in 2022 from one of the 10, but declined to reveal the person’s name. It has filed a police report.
Hours after ST’s article was published, Rainbow Centre acknowledged it had received $72,450 from three of the 10 accused and it will be reviewing its policies.
It had received $30,000 from Turkish national Wang Shuiming, 42, also known as Vang Shuiming. He faces five charges – one for using a forged document and four for money laundering.
It also received $25,350 from Su Haijin, and $17,100 from Zhang Ruijin.
It said it began an internal investigation in August and sought advice from the authorities on the donations, while awaiting an official advisory from the COC.

A lawyer said charities which accept donations from dubious donors can face significant legal penalties, which may involve freezing of their assets or confiscation of the illegal funds.
In May 2015, the COC published a guide for charities about money laundering and terrorism financing.
It said although there has been little evidence local charities are exploited by money launderers or terrorist organisations, they are still vulnerable.
It added: “Such abuse cannot be tolerated and the impact of even one proven case will corrode public confidence in the affected charity and the entire sector.”
It encouraged charities to have vigorous financial controls in place and to be transparent in their activities in order to protect themselves.

The publication listed some money laundering red flags.
These included donors who provide insufficient information; many fund transfers in small amounts to avoid being noticed; corporate donations made with a personal account, and donations which do not seem to match the donor’s known income.
Mr Robin Lee, chief executive officer of Food from the Heart (FFTH) said it did not receive donations from the 10 accused.
He said when FFTH receives donations of more than $20,000, be it in one or several transactions within a month, their fundraising staff would check and verify the donor’s background.
A spokesman from Habitat for Humanity Singapore said when the case broke, the team checked through donations from the last six years. As of now, it has not found any donations connected to the case.
Ms Nichol Ng, Food Bank Singapore’s co-founder, said it was challenging for charities to scrutinise every donor, due to manpower shortage with daily operations.
She added with obligations under the Personal Data Protection Act, their hands may be tied when asking donors about their background.
Mr Abhimanyau Pal, the chief executive officer of another charity, SPD, said: “We hope that recent reports on money laundering activities and the prevalence of scams will not discourage the public from continuing to donate to legitimate causes and charities, which rely on the contributions of the community to support the vulnerable in our society.”
 

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Money laundering accused proposes 24-hour surveillance but fails in latest bid for bail​

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Vang Shuiming was in the High Court on Thursday, the second time the 42-year-old has appealed for bail through a procedure known as criminal revision. PHOTOS: CEL GULAPA, SINGAPORE POLICE FORCE
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Selina Lum
Senior Law Correspondent

Oct 12, 2023

SINGAPORE - A High Court judge has refused bail for Vang Shuiming, one of the 10 foreigners charged in Singapore’s largest money laundering probe, even with the Turkish national’s offer to be placed under 24-hour surveillance as a condition of his release.
Justice Vincent Hoong said the measures proposed did not satisfactorily address the significant flight risk that he posed, given his significant assets overseas, his multiple passports and the investigative finding that his cryptocurrency assets had been moved after his arrest.
Vang, who is also known as Wang Shuiming, was in the High Court on Thursday, the second time the 42-year-old had applied for bail through a procedure known as criminal revision.
He is the only one out of the 10 accused people to have done so.
In the current application, his lawyer, Mr Wendell Wong, argued that a district judge’s order on Sept 29 denying his client bail was wrong.
Justice Hoong said he did not find that there was anything palpably wrong in the order that resulted in serious injustice because Vang was denied bail.
“The arguments made by the applicant before the district judge and in this application are unmeritorious and do not support his position for bail to be granted,” he added.

The judge reminded Vang that while the option remained open to him to seek another bail review in the lower court or file further applications to the High Court for bail to be granted, he must ensure that there were proper grounds to support his applications.
“Once an application for bail has been rejected, the court would be extremely reluctant to grant bail where subsequent applications are filed to the same court, unless there has been a material change in circumstances or new facts have since come to light,” he said, citing a precedent.
Vang, who also has passports from China and Vanuatu, was among the nine men and one woman arrested by the Commercial Affairs Department on Aug 15 and charged the next day. All were originally from China.

The value of the assets seized or frozen by the authorities currently stands at $2.8 billion.
On Thursday, Mr Wong argued that Vang should be granted bail with sufficient conditions to secure his attendance for his trial.
Mr Wong said Vang could be made to wear an electronic tag, and Vang was willing to be placed under 24-hour closed-circuit television camera surveillance.
His family members were also willing to surrender all their passports and have their names put on the Immigration and Checkpoints Authority’s watch list, said the lawyer.
Mr Wong argued that there was no evidence that his client was a flight risk apart from the fact that he had multiple passports, stressing that all the passports were legitimately obtained and issued by the respective governments.
He argued that the presumption of innocence had been overshadowed, even though Vang had never been convicted of any crimes.
However, Deputy Public Prosecutor David Koh maintained that Vang posed a high flight risk.
The prosecutor argued that Vang had no true roots in Singapore as he was neither a citizen nor a permanent resident.
He noted that substantial assets of more than $240 million in the name of Vang and his wife had been seized or subject to prohibition orders in Singapore.
Vang also had more than $35.5 million in assets overseas, the DPP added.
“This provides him with the means and the motivation to move overseas and access the assets which are not seized,” he said.

The prosecutor noted that Vang had been “vague” about the location of his Cambodian passport, which has not been found.
He said Vang’s claim that he and his family members were willing to surrender their passports was meaningless.
“It is not possible for the police to determine how many passports they have, whether all of their passports had been surrendered and... to prevent them from obtaining new passports,” he said.
As for the watch list, the prosecutor pointed out that an accused person who wanted to flee jurisdiction would not necessarily do so through the immigration checkpoints.
In his judgment, Justice Hoong noted that Vang had obtained passports from Turkey, Vanuatu and Cambodia by making donations and financial contributions to those countries.
He said this amplified the risk of Vang being able to abscond, whether by using the Cambodian passport or by procuring a new passport through similar methods.
Vang faces five charges – one for using a forged document and four for money laundering.
He is alleged to have submitted a forged bank statement to Citibank Singapore in March 2021 as supporting documentation.

The money laundering charges relate to about $2.4 million held in four bank accounts. The sums are said to be benefits from an unlicensed moneylending business in China.
Vang’s case is scheduled for a pre-trial conference in the State Courts on Oct 27.
His brother, Wang Shuiting, is one of eight fugitives who are wanted by the Singapore police in connection with the case. The two brothers are on China’s wanted list for illegal gambling activities.
Separately, Rainbow Centre, the operator of three special education schools, has acknowledged that it received donations from Vang and two others of the 10 charged.
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Rainbow Centre, the operator of three special education schools, received $25,350 from Su Haijin, one of the 10 foreigners charged in Singapore’s largest money laundering probe. PHOTO: WECHAT
According to its annual report, Vang donated $30,000. It also received $25,350 from Su Haijin and $17,100 from Zhang Ruijin.
Su, a Cypriot national, faces one charge of unlawfully evading arrest, as well as a money laundering charge involving about $4 million in a UOB bank account, allegedly the benefits of criminal conduct.
At a pre-trial conference on Wednesday, a district judge directed the prosecution to be ready to proceed with the current two charges against Su if the investigations still cannot be completed within eight weeks.
 

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Small charities still using pen and paper to do their accounts: Ex-Commissioner of Charities​

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Several charities had said it was difficult for them to monitor every donation or donor, as they didn’t have the manpower or resources to do so. PHOTO ILLUSTRATION: PEXELS
Samuel Devaraj and Christine Tan

OCT 15, 2023

SINGAPORE - Many small charities in Singapore still rely on manual accounting systems to keep track of their finances.
This involves recording donations using pen and paper, said Professor Ang Hak Seng, chairman of the Institute of Singapore Chartered Accountants’ (ISCA) charity accounting committee.
The former Commissioner of Charities (COC) was speaking with The Straits Times on Friday in an online interview about a new programme by ISCA, the COC and the National Council of Social Service, to help charities digitalise their accounting and finance processes.
The issue of charities accepting tainted donations has been in the news lately after ST reported last week that several had received money from some of the 10 people charged in Singapore’s largest money laundering case.
Several charities had said it was difficult for them to monitor every donation or donor, as they did not have the manpower or resources to do so.
Although ISCA’s programme was not conceived because of the case, it is hoped it would address some challenges smaller charities face.
Prof Ang, who was the COC between 2017 and 2020, said: “Small charities by nature would not have the economies of scale to have digital accounting systems. So they resort to pen and paper.”

The former senior assistant commissioner of the Singapore Police Force, and chief executive director of the People’s Association, said trust is at the core of charities, and it is important for them to have a proper accounting system, so members of the public will feel there is proper accountability when they make donations.
He added: “An example of ensuring good trust is when a charity receives donations, it has to do due diligence. Any time when the charity is not sure regarding the source or the legitimacy of the funds, it should immediately alert the COC.
“Only then can we ensure the whole system is trustworthy.”

ISCA said the new programme started with a pilot involving four charities that used pen and paper to keep their accounts.
It will be expanded in early 2024, with plans to reach over 2,000 charities, especially smaller ones – they form the bulk of charities here – with limited resources.
Four accounting firms – Helmi Talib Accounting & Advisory, Nexia Singapore, Singapore Corporate Services, and Unity Assurance – will offer their services for free.
Xero, an online accounting-software company, will offer a discounted accounting-software package to help charities digitalise their operations.

ISCA said charities faced challenges in resources, particularly the ability to hire qualified chartered accountants.
It said: “There is also little awareness on the importance of having a proper governance framework and little knowledge about the digitalisation of the finance function.”
According to the COC’s 2020 report, smaller charities with annual receipts of less than $500,000 formed the bulk of the total number of charities.
ISCA said the planning for its programme started in the first quarter of 2023 and is not related to Singapore’s worst money laundering case, which has seen the authorities seize $2.8 billion in cash and assets.
Nine men and one woman, originally from China, were charged on Aug 16 with offences including money laundering, forgery and resisting arrest.
Over the past week, ST reported how several charities received donations from some of the 10 accused.
Rainbow Centre said it had received $72,450 from three of the 10 people, and will be reviewing its policies. Lions Befrienders, a social service agency that aids the elderly, said it received $5,000 from one of the 10 in 2022 and has lodged a police report.
The name of one of the 10 also appeared in the National Kidney Foundation’s annual reports from 2020 to 2022, in a list of people who donated at least $5,000 annually to the organisation.
The Community Chest received $30,000 and the President’s Challenge got more than $350,000 from individuals whose names are similar to those of the people charged.

ISCA said the review of processes and digitalisation of accounting systems can help charities spot red flags and improve existing finance policies and governance structures.
It added: “For example, with the linkage of accounting solutions with banks, charities would be able to track incoming donations in a timelier manner, so appropriate due-diligence checks can be performed as needed, for example, on large one-time donations from unknown sources.”
ISCA said charities should consider using anti-money laundering screening tools to help identify suspicious identities or transactions.
Ms Victoria Ting, associate director at Setia Law, said it was not so much a question of charities’ accounting systems, but rather how alive they are to the risk of illicit proceeds and how well equipped they are to counter the risk.
The former deputy public prosecutor, who specialised in white-collar crime, said one simple check even small charities can do, when receiving a large donation from a new donor, is to conduct an Internet search to see if the individual has been implicated in any financial crime.
Ms Ting added: “Charities can also be vigilant with large donations which appear to be broken up into smaller amounts over a short period of time for no apparent reason, as this may suggest the donor is attempting to circumvent reporting requirements. This is also known as smurfing.”
Ms Nichol Ng, co-founder of Food Bank Singapore, said smaller charities may not have the framework or regulatory know-how to ensure there are checks and balances in place.
On tracking suspicious donations, she said: “From the charity standpoint, most of us feel like this is beyond us. How do we check where the money comes from?
“Even if you took it from a legitimate businessman, you’ll never know if the money is clean or not.”
While ISCA’s new programme would be helpful, she said it would need to be easy for charities to understand and adopt.
A spokeswoman for the Singapore Red Cross said it did not receive donations from the 10 persons in the case.
She said it records the particulars of walk-in cash donors, but most donations come through the banking system, and this is a major source of assurance that donations are legitimate.
In May 2015, the COC published a guide for charities about money laundering and terrorism financing.
It said: “Such abuse cannot be tolerated, and the impact of even one proven case will corrode public confidence in the affected charity and the entire sector.”
 

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Billion-dollar money laundering case: Charities urged to review donor records from Jan 2019​

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Over the past week, The Straits Times reported how several charities received donations from some of the 10 accused in the case. PHOTO: SINGAPORE POLICE FORCE
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Samuel Devaraj

OCT 15, 2023


SINGAPORE – The Commissioner of Charities (COC) on Friday urged charities to review their donor records from as far back as January 2019, to see if persons of interest linked to the $2.8 billion money laundering case had donated money to them.
In an advisory seen by The Straits Times, the COC said charities should file suspicious transaction reports if they have reasonable grounds to suspect that any cash or in-kind donations may be connected to any criminal activity.
The advisory included a list of persons of interest in Singapore’s largest money laundering case, to facilitate the review.
It added: “Charities that have received donations from the persons of interest and/or related entities should carefully consider the action(s) you will take in respect of these donations, bearing in mind the potential legal and reputational risks if it comes to light that your charity had accepted donations from the persons of interest and/or related entities.”
Over the past week, ST reported how several charities received donations from some of the 10 accused in the case.
On Aug 15, more than 400 officers led by the Commercial Affairs Department raided properties in locations including Tanglin, Bukit Timah, Orchard Road, Sentosa and River Valley.
Nine men and one woman, who were all originally from China, were charged the next day with offences including money laundering, forgery and resisting arrest.

The first sign of trouble appeared in 2021 when the authorities noticed possibly forged documents being used to substantiate sources of funds in bank accounts here, Second Minister for Home Affairs Josephine Teo said in Parliament on Oct 3.
After an extensive probe in 2022, the police uncovered a web of people allegedly transferring money, which was suspected to be earned from criminal activities, to Singapore from abroad.
Some of the people were connected by family ties.


Some of the accused were said to have been involved in charitable activities before their arrest.
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The 10 suspects are (clockwise from top left) Su Baolin, Su Haijin, Chen Qingyuan, Su Wenqiang, Lin Baoying, Zhang Ruijin, Wang Dehai, Su Jianfeng, Vang Shuiming and Wang Baosen. ST ILLUSTRATIONS: CEL GULAPA
On Aug 30, Chinese national Zhang Ruijin’s defence lawyer, in arguing for his client to be granted bail, said in court he had been active in doing charity work, and had donated to local charities. Zhang, 44, faces three forgery charges.
According to court submissions from the prosecution last Thursday, Turkish national Vang Shuiming, 42, who is also known as Wang Shuiming, obtained passports from Turkey, Vanuatu and Cambodia by making donations and financial contributions to those countries.

Vang faces five charges – one for using a forged document and four for money laundering.
Mrs Teo, who is also Minister for Communications and Information, said on Oct 3 that some of the local charities that received the donations had ring-fenced the money, while others had lodged police reports and planned to surrender the cash to the police.
She added then that the COC would be issuing an advisory to encourage all charities to review donor records.
Among the organisations that confirmed they had received money from the 10 accused was Rainbow Centre. It said it had received $72,450 from three of the 10 people, and that it will be reviewing its policies.

The Community Chest received $30,000 and the President’s Challenge got more than $350,000 from individuals whose names are similar to those of the people charged.
Lions Befrienders, a social service agency that serves the elderly, said it received $5,000 from one of the 10 in 2022 and lodged a police report.
The name of one of the 10 also appeared in the National Kidney Foundation’s annual reports from 2020 to 2022, among a list of people who donated at least $5,000 annually to the organisation.
 

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$2.8b money laundering case: Luxury yacht linked to 2 accused listed for sale at more than $21m​

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The 38m-long Benetti Fast 125 yacht sails under the Cook Islands’ flag, according to brochures put online by the brokers. ST PHOTO: JASON QUAH
Andrew Wong

OCT 15, 2023

SINGAPORE – A luxury yacht linked to the $2.8b money-laundering bust in Singapore has been listed for sale at US$15.5m ($21.2 million).
Checks by The Straits Times showed a number of yacht brokers based overseas had advertised the vessel named “Family” for sale from Sept 13, less than a month after nine men and one woman were arrested on Aug 15 in an operation led by the Commercial Affairs Department (CAD).
The vessel is linked to two of the accused – Su Haijin and Su Baolin – who are allegedly co-owners. Three other owners of the yacht had left Singapore before or soon after investigations started.
Cypriot national Su Haijin, 40, faces one charge of money laundering and another for resisting arrest. Cambodian national Su Baolin, 41, faces two forgery charges. They are both originally from China.
ST contacted brokers Worth Avenue Yachts, Yacht and Villa, and Yacht World last Tuesday about the availability of the Italian-made yacht, which was built in 2020.
A representative of Worth Avenue Yachts said Family remains available for sale as at last Thursday, while Yacht World said it was not aware that the vessel was the subject of some scrutiny in an ongoing probe in Singapore.
The 38m-long Benetti Fast 125 yacht sails under the Cook Islands’ flag, according to brochures put online by the brokers.

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The vessel is linked to two of the accused – Su Haijin (left) and Su Baolin – who are allegedly co-owners. ST ILLUSTRATION: CEL GULAPA
The yacht was previously named Jacozami and owned by British millionaire Jason Peter Clarke. Mr Clarke is listed as a significant shareholder in PHMG, an audio branding company registered in Britain.
It was put up for sale in February 2022 at €17.5 million (S$25.2 million), and the same year Su Haijin and Su Baolin made payments for a superyacht, according to an affidavit presented in court on Sept 8 by CAD officer Thia Yang Shen.
The vessel, which was built by Italian luxury-yacht builder Benetti, boasts four decks, with a master suite and four cabins. The bedrooms have attached bathrooms.


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The yacht was previously named Jacozami and owned by British millionaire Jason Peter Clarke. PHOTO: WORTH AVENUE YACHTS
The yacht also includes a jacuzzi and can accommodate up to 10 passengers and seven crew members.
ST had reported on the link between Su Haijin and the luxury yacht in August, before it left Singapore waters. It was then docked at One°15 Marina in Sentosa Cove, where it costs about $20,000 a month in berthing fees for a superyacht.
The authorities in Singapore had initially blocked the vessel from leaving the marina, but it was cleared to depart on Aug 19. It then sailed westwards before the tracking device on board was apparently switched off.
Craft Docket, a yacht and crew clearance provider hired to manage the vessel, told ST in September that the yacht was registered to an individual whose name does not match any of the 10 accused.
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The yacht also includes a jacuzzi and can accommodate up to 10 passengers and seven crew members. PHOTO: WORTH AVENUE YACHTS
The CAD affidavit revealed that it was registered in the name of a fifth individual, who had also left Singapore.
Yacht brokers from Worth Avenue Yachts and Yacht World declined to reveal the name of the registered owner. “If there is an issue with that yacht, the authorities should investigate. The yacht is in front of them,” Worth Avenue Yachts said.
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The vessel, which was built by Italian luxury-yacht builder Benetti, boasts four decks, with a master suite and four cabins. PHOTO: WORTH AVENUE YACHTS
The police declined to comment when asked why the vessel was allowed to leave Singapore waters, citing ongoing investigations.
They also would not say if the yacht has been issued with a prohibition of disposal order, which was slapped on 152 properties and 62 vehicles, valued at more than $1.24 billion in total.
The orders mean they cannot be sold. The total value of assets linked to the case has risen to more than $2.8 billion.
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Yacht brokers from Worth Avenue Yachts and Yacht World declined to reveal the name of the registered owner. PHOTO: WORTH AVENUE YACHTS
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Money laundering accused fails in latest bid for bail
About $1b in cash, assets seized and frozen in one of S’pore’s biggest anti-money laundering operations

Multiple raids​


The operation on Aug 15 involved more than 400 police officers and saw raids at properties in areas such as Tanglin, Bukit Timah, Orchard Road, Sentosa and River Valley.
Ten foreigners, all originally from China, were charged the next day with offences including money laundering, forgery and resisting arrest. It is Singapore’s worst money laundering case and one of the world’s largest.
Mr Thia’s affidavit showed that the police had seized or issued prohibition of disposal orders against the assets of Su Haijin and his wife Wu Qin worth $171,340,000, including more than $120 million in properties and over $2.6 million in vehicles.
In a separate affidavit, CAD officer Louis Tey Jijie said the police had seized or issued prohibition of disposal orders against the assets of Su Baolin and his wife Ma Ning worth $99,094,000.
These include more than $57 million in properties and about $4.9 million in vehicles.
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The authorities in Singapore had initially blocked the vessel from leaving the marina, but it was cleared to depart on Aug 19. PHOTO: WORTH AVENUE YACHTS
Aside from the vessel, Su Haijin and Su Baolin purportedly had property dealings as well.
Prosecutors said Su Baolin had allegedly paid $2.2 million in 2021 in Su Haijin’s name towards two properties in Beach Road.
 

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Money laundering case: Woman lived on Sentosa with lover, not daughter; S’pore roots overstated, says DPP​

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Lin Baoying, the only woman accused in the $2.8 billion money laundering case, is said to have lived on Sentosa with Zhang Ruijin, described as her “domestic partner”. ST ILLUSTRATIONS: CEL GULAPA
Christine Tan and Samuel Devaraj

Oct 18, 2023

SINGAPORE – The only woman accused in the $2.8 billion money laundering case is said to have lived on Sentosa while her 15-year-old daughter lived with a maid in Beach Road.
The person the woman was living with in a Sentosa Cove bungalow was her lover, who is also one of the accused in Singapore’s worst money laundering case.
In Lin Baoying’s bail review on Wednesday, Deputy Public Prosecutor Nicholas Tan said the 44-year-old Chinese national, who had claimed she lives in Singapore with her daughter, had been less than candid with the court.
He said: “In reality, the daughter resides in Singapore but not with the accused. They stay at separate residences.”
The DPP said the prosecution was not insinuating that Lin did not intend to fulfil her motherly duties, but argued that her claim to be rooted here because of her daughter was overstated.
He added that the daughter was receiving adequate care while Lin was in remand, and it was clear they had separate living arrangements before her arrest.
In arguing for bail, Lin’s lawyer Chew Kei-Jin said his client, who faces two charges of forgery and one of perverting the course of justice, was first interviewed by police in June 2022. She then left Singapore twice and returned each time.

He said this was not something a person seeking to abscond would do.
The first sign of trouble that led to the discovery of Singapore’s largest money laundering case was in 2021, when the authorities noticed possibly forged documents being used to substantiate sources of funds in bank accounts here, Second Minister for Home Affairs Josephine Teo said in Parliament on Oct 3.
Mrs Teo said that after an extensive probe in 2022, the police uncovered a web of people allegedly transferring money, suspected to be earned from criminal activities, to Singapore from abroad.

In arguing against bail, DPP Tan said Lin has passports from countries which she has no substantive ties to, including Turkey, Cambodia, and Dominica – a country she has never been to.
The prosecutor said Lin obtained the Dominican passport after paying US$130,000 (S$177,900) to an agent and the Cambodian one after paying US$160,000.
The DPP said the manner in which she bought the passports meant she could do so again through similar methods.
Mr Chew said that apart from a social connection with four of the other accused individuals in the case, Lin has not been shown to be connected to the others.

One of these connections was to Zhang Ruijin, 45, whom Mr Chew described as Lin’s “domestic partner”.
It was revealed in court on Aug 16 that Lin and Zhang – who were among 10 foreigners charged in connection to the case – were lovers.
Referring to Lin, Zhang had told the court: “You can separate her crimes from me, we are just lovers... You can bail me out, but remand her.”
According to an affidavit from Commercial Affairs Department (CAD) officer Seow Jing Min, the pair have known each other for more than a decade.
Lin calls Zhang her husband, though they are not officially married, said Ms Seow in the affidavit.
In response to Mr Chew’s claim that Lin had only a social connection to four of the accused, DPP Tan said these connections were not simply about meals and gatherings, but that Lin had gone on holidays with Zhang, and with two other accused individuals – Su Baolin and Su Haijin – and their wives.
Zhang, who faces a total of three forgery charges, also had his bail reviewed on Wednesday.
In arguing for bail, Zhang’s lawyer Loo Choon Chiaw said his client was incapable of absconding as he did not have the means to do so. He said Zhang only had $93,000 left in his personal funds.
Mr Loo said his client was gainfully employed as the chief investment officer of Golden Eagle Family Office, which further demonstrated his ties to Singapore.
Zhang has lived in Singapore for about four years, and wanted to raise a family here with Lin before their arrests, said Mr Loo, adding that these plans have not changed despite the current circumstances.
He said his client had also been interviewed in June 2022 and made two overseas trips – to Europe in July 2022 and Maldives in April 2023. He returned, proving he had no intention to abscond.
DPP Tan said Zhang had set up Golden Eagle to manage his wealth, and that was essentially the only function of his business.
The prosecutor said the company was dependent on Zhang to function, and given that his known wealth had been seized, the existence of this company was now in question. Therefore, it cannot be considered a significant root in Singapore.

On Aug 15, more than 400 officers led by the CAD raided properties in various locations, including Tanglin, Bukit Timah, Orchard Road, Sentosa and River Valley.
Nine men and one woman, all originally from China, were charged the next day with various offences, including money laundering, forgery and resisting arrest.
Among the assets the authorities have taken control of are 152 properties and 62 vehicles with an estimated value of more than $1.24 billion, money in bank accounts amounting to more than $1.45 billion, and cash in various currencies worth more than $76 million.
Another of the accused, Wang Dehai, 34, also had his bail application heard on Wednesday.
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Among the assets the authorities have taken control of are 152 properties and 62 vehicles with an estimated value of more than $1.24 billion, money in bank accounts amounting to more than $1.45 billion, and cash in various currencies worth more than $76 million. PHOTOS: SINGAPORE POLICE FORCE
DPP Edwin Soh said Wang Dehai had relatives who were part of a remote gambling business operating from the Philippines and may help him leave the country.
In arguing against bail for Wang Dehai, the prosecutor said his brother-in-law Su Yongcan and his cousin Wang Huoqiang were accomplices who might help him abscond.
The Straits Times reported on Aug 21 that Su Yongcan, 32, and Wang Huoqiang, 29, were said to be on the run in 2018. Both men were known associates of Wang Dehai and two other accused – Vanuatu national Su Jianfeng, 35, and Cambodian national Su Wenqiang, 31.
Su Yongcan and Wang Huoqiang were among 72 individuals the authorities in China investigated in 2017 as they clamped down on illegal gambling activities.
Wang Dehai, a Cypriot national, faces two charges under the Corruption, Drug Trafficking and other Serious Crimes (Confiscation of Benefits) Act (CDSA). He was arrested at his condominium, The Marq on Paterson Hill, near Orchard Road.
He allegedly used proceeds from the illegal online gambling service – which is based in the Philippines and is for customers in China – to buy The Marq apartment for $23 million in November 2019.
He also allegedly possessed $2.3 million from illegal remote gambling offences.

On Wednesday, DPP Soh said investigations show the money can be linked to such illegal gambling operations and that the prosecution has produced credible evidence that Wang Dehai committed the offences stated in the charges.
Wang Dehai’s defence lawyer Megan Chia said her client’s involvement in remote gambling between 2012 and 2016 was insufficient to prove he had committed the offences he had been charged with.
DPP Soh said that even if remote gambling was legal in the Philippines, Wang Dehai had offered it to people in China, and a wanted notice in China for Wang Dehai made it evident that the service was illegal there.
The DPP referred to an affidavit submitted by Ms Chia which stated that Wang Dehai had left China after the wanted notice was issued as he felt the potential sentence would suspend his civil liberties.
With Wang Dehai now facing more serious charges in Singapore, the DPP said he would surely be motivated to abscond to avoid a lengthy prison term.
District Judge Terence Tay adjourned his decision on Wang Dehai, Lin Baoying and Zhang Ruijin’s bail to Wednesday afternoon.
On Wednesday morning, another of the accused, Cambodian national Chen Qingyuan, 33, was scheduled to have his bail reviewed. But the review was postponed as he had recently changed lawyers.
His new lawyer, Mr Gary Low, said he had taken over the case 2½ weeks ago and had filed an affidavit for his client on Tuesday. He said the prosecution had indicated it would require till Nov 3 to respond.
Chen who faces four charges under the CDSA, will return to court on Nov 17.
 

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Singapore to inspect Credit Suisse, others in B$2bn scandal​

bangkokpost.com/business/general/2666531/singapore-to-inspect-credit-suisse-others-in-2-billion-scandal

18 Oct 2023

SINGAPORE - Financial regulator in Singapore will conduct an on-site inspection of Credit Suisse Group AG after at least one of its customers was charged for money laundering in a scandal that has rocked the city-state.

The local unit of Credit Suisse will be among banks the Monetary Authority of Singapore plans to examine to determine whether they properly handled the monitoring of wealthy clients, according to people familiar with the matter. Officials from the regulator are set to interview personnel and review documents within weeks, the people said, asking not to be identified as the information is not public.

The planned inspection underscores the seriousness of the scandal that has ensnared at least 10 domestic and international banks in the Asian financial hub. More than S$2.8 billion (US$2 billion) of assets from cash to jewellery have been seized from a group of alleged money launderers with Chinese origin.

The MAS’s upcoming visit would be outside its regular engagements with banks and signals potential issues with the lenders’ sizable exposure to the suspects and overall handling of client vetting, the people said. Credit Suisse is among the banks that have relationships with either the accused, or their companies. One of the suspects, Vang Shuiming, held S$92 million at the Swiss lender, the biggest known account so far in the case.

Credit Suisse declined to comment. An MAS spokesperson referred Bloomberg News to comments made in parliament this month by Minister of State Alvin Tan, who said the regulator is conducting supervisory reviews and inspections of the banks with "a major nexus" to the case. Tan also said it was concerning that financial assets made up the vast bulk of what was seized so far.

Vang also had bank accounts with others including Bank Julius Baer where he had S$33 million as well as United Overseas Bank Ltd and RHB Bank Bhd's local unit, according to police affidavits. Vang’s other charges include forgery of a bank document to trick Citibank Singapore Ltd.

It is not clear which other banks will be subject to MAS inspection, which could look into what red flags were raised internally and when so-called suspicious transaction reports were filed, the people added.

For Credit Suisse, the review is but one of many headaches its new parent UBS Group AG will have to deal with as it focuses on integrating thousands of employees from its former rival across the world. The MAS did a similar inspection on Credit Suisse in 2017 for its role in the 1MDB saga, Malaysia’s biggest corruption case, and consequently the bank was fined S$700,000. The amount was the smallest penalty the regulator imposed on banks in Singapore at the time.

Scandal aftermath

After the case erupted in August, banks in the city-state have further stepped up existing scrutiny on clients especially those of Chinese origins with multiple passports, Bloomberg reported last month. The authorities are also looking into how one or more of the accused may have been linked to single family offices with incentives and will tighten the rules where necessary.
 

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$2.8b money laundering accused is IT company CEO but does not know where office is: DPPs​

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Vanuatu national Su Jianfeng faces four money laundering charges. ST ILLUSTRATION: CEL GULAPA
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Nadine Chua

Oct 19, 2023

SINGAPORE – A man arrested in the $2.8 billion money laundering case claims to be the chief executive of a computer support firm, but does not even know where his office is.
In fact, investigations show this firm is a shell company, prosecutors said on Wednesday, in arguing against bail for Vanuatu national Su Jianfeng. He faces four money laundering charges.
Deputy Public Prosecutors Edwin Soh and Sarah Thaker said the 35-year-old has no true roots in Singapore, which is proved by his lack of legitimate employment here.
In their submissions to deny him bail, the DPPs said: “He claims that he is the CEO of An Xing Technology, which he purports is an active company with ongoing projects.
“However, investigations show that this is a shell company.”
They added that as at Aug 15, which was when Su and nine others were arrested for their suspected involvement in this money laundering case, An Xing Technology had only a single corporate bank account which was largely dormant.
Said the DPPs: “There were totally no deposits made into this account in 2023.

“Further, and critically, the accused himself said in his statements that despite him being CEO, he is ‘unclear’ of the company’s business and does not even know the location of its office.”
The DPPs said this showed Su had little to no involvement in the firm.
They added: “His assertion that the company somehow roots him to Singapore is without merit.”

The prosecution also noted there were reasonable grounds to believe Su was guilty of the money laundering charges handed to him.
His four charges involve a total of over $17 million, which he claimed was linked to a friend named Ah Ler whom he met in Dubai, said the DPPs.
They said: “According to the accused, this mysterious Ah Ler would be able to ‘attest to the source of funds’. This is glaringly vague.”

Referring to the affidavit written by the investigation officer in Su’s case, the DPPs said no details were provided about the whereabouts, background or contact information of Ah Ler. In fact, investigations showed there was no evidence to suggest that Ah Ler exists.
On Wednesday, Su was denied bail by District Judge Terence Tay.
He had also refused bail for three others involved in this case – Lin Baoying, Zhang Ruijin and Wang Dehai.

In an affidavit, senior investigation officer (SIO) Lim Yong Khiang of the Criminal Investigation Department supported the prosecution’s application that no bail be granted to Wang.
SIO Lim said Wang was a customer service employee who dealt with punters in a Philippines-based online gambling business.
Wang, 34, who faces two money laundering charges, was recruited in 2012 into the online gambling business, which provided remote gambling services to people in China.
SIO Lim said that after working as a customer service employee, the Cypriot national became a promoter, which involved posting advertisements for online gambling on popular websites.
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Wang Dehai was charged in August with being in possession of $2.3 million, which represented his benefits from criminal conduct. ST ILLUSTRATION: CEL GULAPA
He was paid in cash or bank transfers and now owns over $56 million in cash and assets in Singapore and overseas.
He was charged in August with being in possession of $2.3 million, which allegedly represented his benefits from criminal conduct. He was also accused of buying a unit at The Marq on Paterson Hill with $23 million which was, in part, also benefits from criminal conduct.
SIO Lim said evidence showed the money in both charges can be linked to such illegal remote gambling operations that he was allegedly involved in overseas.
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The 10 suspects are (clockwise from top left) Su Baolin, Su Haijin, Chen Qingyuan, Su Wenqiang, Lin Baoying, Zhang Ruijin, Wang Dehai, Su Jianfeng, Vang Shuiming and Wang Baosen. ST ILLUSTRATIONS: CEL GULAPA
Court documents show that more than $42 million of Wang’s assets here were seized, including a property worth $23 million, $2.3 million in cash, $3.7 million of cryptocurrency, $12.6 million in bank accounts and two vehicles worth $550,000.
SIO Lim said Wang admitted to having substantial wealth overseas, including two houses in Xiamen, China, worth around $1.06 million and a house in Cyprus with an estimated value of $2.9 million.
His overseas assets include money in Hong Kong bank accounts amounting to more than $10.4 million.
Separately, $19,000 in cash and $8.9 million in a bank account belonging to his wife, Su Caihuang, were seized.
SIO Lim said CID has prohibited the disposal of jewellery, wines, luxury watches and bags belonging to his wife.

Other accused individuals involved in the case also own substantial assets.
Lin, who is the only woman charged, owns over $215 million worth of assets here, which have been taken control of by the authorities.
These assets include over $9.6 million in cash, $130 million in 14 bank accounts, $1.8 million in cryptocurrency, five real estate properties worth $72 million and two vehicles worth $1.6 million.
The 44-year-old also told investigators she has over $30 million worth of assets overseas, including six residential properties in the United Kingdom worth $10 million and properties in the Philippines and Dubai.
Meanwhile, at least $109 million in assets linked to Lin’s lover Zhang, 45, were seized or subjected to prohibition of disposal orders.
These include four properties worth $27 million, four vehicles worth $5.4 million, over $14 million in cash and $60 million in 13 bank accounts.
 

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From briefcase of cash to virtual wallets: Why financial crimes are harder to catch​

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Angela Tan
Senior Correspondent
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Unlike cash, digital currencies like cryptocurrencies offer one of the easiest methods to move money out of a country. PHOTO ILLUSTRATION: PEXELS

OCT 23, 2023

SINGAPORE - Not too long ago, criminals carried their ill-gotten cash in briefcases to dodge banking scrutiny and the police.
With technological advancements, many have turned to the virtual world and digital currencies, making it harder for the authorities to trace the more than US$800 billion (S$1.1 trillion) estimated to be laundered globally every year.
Mr Chenthil Kumarasingam, a partner at Withers KhattarWong’s dispute resolution practice, told The Straits Times that criminals employ various methods to circumvent most countries’ capital controls by using sophisticated tactics to disguise the true nature and origin of the funds.
“These methods are designed to misrepresent or disguise the actual amounts of money being moved, making it difficult for authorities to detect or trace these illicit transfers,” said Mr Kumarasingam.
The creativity and complexity of these schemes often rely on a deep understanding of financial, legal and regulatory systems, both within and outside the country, he said.
Unlike cash, digital currencies like cryptocurrencies offer one of the easiest methods to move money out of a country, even from places like China, which has one of the world’s strictest capital controls, and Russia, which has been sanctioned by the West for its attack on Ukraine.
There are many cryptocurrencies. Many are not regulated and not traceable, effectively allowing anyone to move funds around without much scrutiny, experts said.

Criminals take advantage of unregulated cryptocurrency exchanges that do not require proof of identification or registration information to move funds, said CipherTrace, a crypto intelligence company.
With the explosion of crypto values in 2021, and the creation of overnight millionaires, these virtual coins became a credible and acceptable form of new wealth.
A retired Singapore banker recalled how he once overheard a bank officer dutifully asking a customer about his source of funds. When informed that the money was profit from trading in cryptocurrencies, the bank officer congratulated the customer and proceeded to ask him to teach her how to get rich from crypto, too.

However, using cryptocurrency has its limitations, as it is not a scalable operation, experts said.
It is very hard to shift huge amounts “because you would have to do so in many transactions in order to hide the sources, and it’s too time-consuming”, said a financial crime compliance consultant.
Cryptocurrencies, worth millions, were found in Singapore’s $2.8 billion money laundering case which is still unravelling.

Students as money mules​

Experts said illicit funds are transferred out of a country either through an individual or a business.
An individual, especially a young person who is allowed entry into a foreign land to study on a student pass, tends to attract less scrutiny.
Earlier in October, British bank Barclays issued an urgent warning about a surge in student money mules, who knowingly or unwittingly let criminals use their bank accounts to move money.
Barclays said two in five money mules in Britain are under the age of 25, and one in five is under 21.
Mr Ross Martin, head of digital safety at Barclays, said criminals target young people using social media to advertise get-rich-quick schemes, job applications which require payments through their personal bank accounts, online dating, investments, cheap loans and refunds.
Non-fungible token (NFT), a form of digital asset that is used to certify ownership and authenticity of a digital file such as an image, video or text, is another conduit that has gained traction in recent years.
The total value of all NFT transactions worldwide stood at a staggering US$17 billion at its peak in 2021, according to NFT data company Nonfungible.com. But most NFTs are now worthless, and struggling to find buyers.
This is because NFTs are only as valuable if someone else is willing to pay for it, making them susceptible to criminal manipulation, experts said.
Criminals use illegal funds to buy NFTs and proceed to transact among themselves to create a record on the network. They can also create their own NFT project and sell them to unwitting individuals.
Many NFT platforms – including OpenSea, the largest NFT marketplace – do not require customer information for its customers, providing an invisible cloak for criminals.

Fake trade deals​

Like NFTs, art has also been used to move money around.
“These are things that are worth something only if you or someone says so,” a financial crime compliance expert said.
Criminals also employ trade-based money laundering methods, under the guise of legitimate trade deals, to move money out of a country. They may over-invoice or under-invoice the value of goods and services in trade transactions.
Mr Kumarasingam said: “For example, a Chinese company might export goods worth $1 million but invoice the foreign buyer $2 million. The foreign buyer who is in on the scheme then pays the inflated amount, and the excess $1 million is moved out of China illicitly.”
In the past, gold and diamonds were extremely attractive vehicles for money laundering. But these days, criminals are using rare metals, given that their values are hard to ascertain.
Money is also moved outside the formal banking system using informal value transfer systems such as remittance companies or unlicensed money brokers to hide cross-border payments.
This transfer method involves depositing money in one location and withdrawing the equivalent value in another.
“Funds are transferred without any money actually crossing borders, relying on trust within tightly knit communities,” said Mr Kumarasingam.
Criminals often set up companies in jurisdictions with strict secrecy laws. For instance, an individual in China might “loan” money to his own shell company outside of China.
“This is not seen as a capital transfer but as a business transaction. The funds are then withdrawn or used abroad without breaching the capital controls,” Mr Kumarasingam said.

Some leverage legal structures to avoid scrutiny.
Financial crime experts said it is “almost impossible” to unravel criminal connections after more than five years.
This is in spite of the fact that the Inland Revenue Authority of Singapore mandates that companies must keep proper records and accounts of all business transactions and retain them for at least five years.
Banks are required to present up to seven years of record, if there is a legal case that requires documents to be shown as evidence.
One financial crime compliance expert said: “Criminals typically do not use the same financial institution for too long. They maintain relationships with several banks in order to minimise the banking trail.
“This confuses and complicates investigations.”
He said financial crimes like money laundering will continue to test financial systems globally.
“It’s just the nature of the beast.
“You will never catch everything because if you do, that means you create so much pain and paperwork, even for the good
 
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