Anti-Money Laundering Resources

Anti-Money Laundering Resources

Anti-Money Laundering

This page provides information and guidance to lawyers and law practices on their Anti Money Laundering, Countering the Financing of Terrorism and Proliferation Financing (‘AML/CFT/PF’) obligations.

All legal practitioners in Singapore, including local and foreign lawyers, as well as law practices, must comply with the Anti-Money Laundering (‘AML’) and Countering the Financing of Terrorism (‘CFT’) and Proliferation Financing (‘PF’) regulatory framework. This segment provides to the key legislation, guidance and templates to help legal practitioners and law firms detect and prevent money laundering and terrorist financing.

Regulatory Framework

The Legal Profession (Amendment) Bill was passed on 4 November 2014 and the new Part 5A of the LPA on Prevention of Money Laundering and Financing of Terrorism came into effect together with the Legal Profession (Prevention of Money Laundering and Financing of Terrorism) Rules on 23 May 2015. The regulatory framework will apply to both Singapore lawyers and law practices, as well as foreign lawyers and foreign law practices.

1. Relevant Legislation
  1. Part 5A of the Legal Profession Act 1966 (‘Part 5A’) on the “Prevention of Money Laundering and Terrorism Financing and Financing of Proliferation of Weapons of Mass Destruction” (‘LPA’)
  2. Legal Profession (Prevention of Money Laundering, Financing of Terrorism and Proliferation Financing) Rules 2015 (‘Rules’)
  3. Legal Profession (Prevention of Money Laundering and Financing of Terrorism) (Amendment) Rules 2025 (which came into operation on 1 July 2025)
  4. Terrorism (Suppression of Financing) Act 2002 (‘TSOFA’)
  5. The Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 (‘CDSA‘)
2. Practice Direction on Prevention of Money Laundering & Financing of Terrorism
  1. Practice Direction 3.2.1 sets out directions and guidance on Part 5A of the Legal Profession Act 1966 and the Legal Profession (Prevention of Money Laundering and Financing of Terrorism) Rules 2015.
Tools
Information on High Risk Countries / Jurisdictions & High Risk Individuals / Entities

In considering whether the risks of money laundering and the financing of terrorism are raised (under Rule 12(4) and Rule 13(1)(a) of the Legal Profession (Prevention of Money Laundering & Financing of Terrorism) Rules 2015, including determining whether the client is from or in any country or jurisdiction known to have inadequate measures to prevent money laundering and the financing of terrorism, you may refer to the following links:

  1. MAS’ Webpage on Targeted Financial Sanctions.
  2. FATF’s Webpage on High Risk and Other Monitored Jurisdictions
  3. The Narrative Summaries List established and maintained by the Committee pursuant to resolutions 1267 (1999), 1989 (2011) and 2253 (2015) concerning ISIL (Da’esh) Al-Qaida and associated individuals groups undertakings and entities
  4. The Narrative Summaries List established and maintained by the Committee established pursuant to resolution 1988 (2011) with respect to individuals, entities, groups, or undertakings
  5. Ministry of Home Affairs Alert List (List of persons known to have been involved in terrorism financing related activities)
  1. (click ‘for Lawyers’ > ‘Members Library’ > [Log in with your ID and Password] > ‘Regulatory Matters’ > ‘Anti-Money Laundering’)
Information and Guidance on Countering the Financing of Terrorism

Refer to this link.

Guidance on Analysis of Client Risk, Identification of Material Red Flags, Source of Wealth (‘SOW’) Establishment, Ongoing Monitoring of Clients and their Transactions, and Suspicious Transaction Report (‘STR’) Filing Timeline

Refer to this link.

Circular from the Ministry of Law and Information papers from the Monetary Authority of Singapore on "Cyber Risks Associated with Generative Artificial Intelligence" and "Cyber Risks Associated with Deepfakes"
Training Videos on Proliferation Financing and Filing Suspicious Transaction Reports developed by the  Ministry of Law
Templates (developed by the Law Society of Singapore)
  1. Sample Client Due Diligence Checklist Template
  2. Sample Ongoing CDD Checklist Template
  3. Sample Firm Wide Risk Assessment Template 

Pursuant to section 70D of the LPA, where a legal practitioner or law practice knows or has reasonable grounds to suspect that any property was or is intended to be used in connection with drug dealing or criminal conduct, as set out in section 45(1) of the CDSA, the legal practitioner or law practice must disclose the matter to a Suspicious Transaction Reporting Officer under the CDSA by way of a suspicious transaction report; or an authorised officer under the CDSA. 

There is also a duty under section 8(1) of the TSOFA for every person in Singapore and every citizen of Singapore outside Singapore who has (inter alia) information about any transaction or proposed transaction in respect of any property belonging to any terrorist or terrorist entity, to file a suspicious transaction report. 

For more information on suspicious transaction reporting, please refer to Part 5A of the Legal Profession Act and the Legal Profession (Prevention of Money Laundering and Financing of Terrorism) Rules 2015.

How to file a Suspicious Transaction Report?

A suspicious transaction report can be made directly to the Suspicious Transaction Reporting Office (‘STRO’), which is the central agency in Singapore for the receipt, analysis and dissemination of suspicious transaction reports, under the Commercial Affairs Department (‘CAD’) of the Singapore Police Force. A suspicious transaction report should be filed electronically using the STRO Online Notices and Reporting platform (‘SONAR’) provided by STRO to file STRs. To file STRs on the new SONAR platform, you will need:

  • Adobe Acrobat reader software for your law practice’s designated SONAR users;
  • CorpPass account for your law practice;
  • Access to the CorpPass account for your law practice’s designated SONAR users (select ‘SPF E-Services (G2B)’);
  • SONAR accounts for your law practice’s designated SONAR users (they will need their CorpPass account details to apply for SONAR accounts).

SONAR allows businesses and their employees to file Suspicious Transaction Reports (‘STRs’), Cross Border Cash Movement Reports (CMRs – NP 728) and Cash Transaction Reports (CTRs – NP 759) to STRO on a consolidated platform. It replaces the existing Suspicious Transaction Report Online Lodging System (STROLLS) and Electronic 728 (E728). Along with the launch, three electronic forms have been introduced on SONAR:

  • Form NP 728 for CMRs;
  • Form NP 759 for CTRs; and
  • A new form for STRs.

Should you have any inquiries regarding the E-filing of STR, please contact the SONAR team at SPF_STRO_IT_Team@spf.gov.sg. For the STR Form and filing instructions, you can visit the following websites:

Red Flag Indicators for STRs:
  1. After filing a STR, must a legal practitioner or law practice seek the consent of STRO or seek its directions, before proceeding with the transaction for the client? ​

There is no requirement in the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 for STR filers to seek the consent of STRO or to seek STRO’s directions before proceeding with the transaction for the client.

  1. After an STR has been filed, is there a moratorium during which a legal practitioner or law practice cannot proceed with the transaction for the client? ​

There is no moratorium on transacting for the client after the filing of a STR.

  1. After an STR has been filed on the client, how long must the legal practitioner or law practice wait before continuing to act for the client? ​

After an STR has been filed, the legal practitioner or law practice must consider if it is appropriate to continue a business relationship with the client; or establish a new business relationship with, or undertake a new matter for, the client (rule 5(1)(b) of the Legal Profession (Prevention of Money Laundering, Financing of Terrorism and Proliferation Financing) Rules 2015).

If a decision is made to continue a business relationship with, establish a new business relationship with, or undertake a new matter for the client, the legal practitioner or law practice must substantiate and document the reasons for continuing or establishing the business relationship with, or undertaking the matter for, the client and subject the business relationship or matter to commensurate risk mitigation measures, including enhanced ongoing monitoring (rule 5(2) of the Legal Profession (Prevention of Money Laundering, Financing of Terrorism and Proliferation Financing) Rules 2015).

More information and guidance on the various statutory provisions and obligations relating to STRs is available at Section 5 of Practice Direction 3.2.1 on Prevention of Money Laundering, Financing of Terrorism and Proliferation Financing.  

If STR filers have any queries after a STR has been filed, the STR filer can contact STRO at stro@spf.gov.sg. In cases where queries relate to STRs of which STRO has disseminated the information to law enforcement agencies or foreign financial intelligence units, STRO may require more time to respond.

  1. After an STR has been filed on the client, how does the legal practitioner or law practice terminate the relationship without tipping off the client?

If a legal practitioner or law practice decides to terminate the client relationship, the client or any third party must not be informed that an STR has been filed as this will constitute tipping-off. It is an offence under section 57 of the CDSA and section 10B of the TSOFA to disclose to any other person information or any other matter which is likely to prejudice any investigation which might be conducted following the disclosure. The legal practitioner or law practice should give an appropriate reason to the client for terminating the relationship. For example, compliance requirements could be cited as a reason: 

    1. Risk Management or Compliance Department has instructed to decline representation. We are unable to give details.
    2. The matter does not accord with internal risk management policies, and we are unable to give details.
  1. In the following situation, would the STR filer have any protection from liability?​

Situation: The STR filer holds off acting for the client. Liabilities were incurred during the ‘waiting period’. For example, the real estate transaction option period lapses and the client loses a profit on the sale. The client does not receive his funds needed to complete his business dealings. The client threatens to sue the STR filer for costs or losses incurred by the ‘delay’ of the STR filer.

**STRO noted that there is no answer provided to this question in the FAQs. STRO is of the view that Law Society is best placed to provide the answer. We would like to highlight that section 45(7) of the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 provides that the disclosure of information when filing a STR does not breach any restriction imposed by law, contract or rules of professional conduct and the person shall not be liable for any loss arising out of the disclosure or any act or omission in consequence of the disclosure.

  1. After a STR is filed, will STRO notify the filer of the outcome?​

An acknowledgement email will be sent to the STR filer after a STR is submitted on SONAR. Subsequently, STR filers may check on the status of the STR on SONAR.

Singapore’s Money Laundering (ML) National Risk Assessment (NRA) forms part of Singapore’s continuing efforts to maintain the effectiveness of its anti-money laundering (AML) regime amidst its evolving risk landscape. The MRA synthesises the ML risks as identified by the Singapore law enforcement agencies, the STRO, supervisory authorities, feedback from private sector entities and foreign authorities. 

Click here for more information on the NRA and here for a copy of the NRA.  

You may wish to refer to the following resources for reference: 

Singapore is a member of the inter-governmental body, the Financial Action Task Force (‘FATF‘), set up to combat money laundering and terrorist financing. Ahead of the FATF’s on-site visit of Singapore in 2025, the Ministry of Home Affairs has requested that Law Society’s members subscribe to the Monetary Authority of Singapore’s (‘MAS’) webpage to receive timely updates on changes to UN designations. As Singapore is also a member of the United Nations (‘UN’), Singapore gives effect to the sanctions under the UN Security Council Resolutions. The sanctions are made legally binding through the Regulations issued pursuant to the UN Act (‘UN Regulations’). All persons in Singapore have to comply with the UN Regulations. Among other provisions, the UN Regulations prohibit persons in Singapore from dealing with UN-designated individuals and entities. As above, please refer to MAS’ webpage on Targeted Financial Sanctions for more information on your obligations under the UN Regulations. Any breach of the regulations could subject an individual to a fine not exceeding $500,000 or to imprisonment for a term not exceeding 10 years or to both; or in any other case, to a fine not exceeding $1 million.

Subscriber Services

The Law Society of Singapore strongly encourages all legal practitioners and law practices to subscribe to the MAS mailing list to receive updates to the lists of designated individuals and entities. The subscription is available at Subscriber Services (mas.gov.sg). Click here for an infographic on how to subscribe to the MAS mailing list. Subscribing to the MAS emailing list will alert you to changes to the lists of UN designated individuals and entities, and help you stay abreast of other relevant announcements, such as high risk jurisdictions identified by the Financial Action Task Force (‘FATF’).

FATF Guidance

The Law Society of Singapore specifically developed this e-learning course for legal professionals. The course consists of 5 modules which cover the relevant legislation, frameworks, and provide guidance on AML and CTF.  

For more information and to register for the course, please click here. 

Implementation of Internal Policies, Procedures, Controls
Other Relevant Resources
Historical Archive

If members have any queries relating to the AML and CFT compliance requirements applicable to lawyers and law practices, the query may be first referred to the Anti-Money Laundering Secretariat at AmlSecretariat@lawsoc.org.sg.

On This Page

Services
Guidance & Notices