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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.
AML Resources

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. With this new legislation coming into force, rules 11(D) to 11(I) of the previous Legal Profession (Professional Conduct) Rules > are repealed forthwith. 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. The Legal Profession (Prevention of Money Laundering and Financing of Terrorism) Rules 2015 (‘Rules’)
  3. Terrorism (Suppression of Financing) Act 2002 (‘TSOFA’)
  4. 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

a.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.

Templates

  1. Sample Client Due Diligence Checklist developed by the Law Society of Singapore. A key requirement for law practices is the development and implementation of internal policies and procedures to prevent money laundering and the financing of terrorism.
  2. Sample Firm Wide Risk Assessment Template developed by the Law Society of Singapore. Law firms should take the appropriate steps to identify, assess and understand its money laundering and terrorism financing risks, with consideration of its size, type of clients, countries or jurisdictions its clients are from and the practice area it engages in.
Suspicious Transaction Reports ('STRs')
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:

Frequently Asked Questions ('FAQs') on STROs
1. After filing a STR, must a law practice or a lawyer 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.
2. Is there is a moratorium following the filing of a STR during which a law practice or a lawyer cannot proceed with the transaction for the client?​
There is no moratorium on transacting for the client after the filing of a STR.
3. After a law practice or a lawyer has filed a STR on the client, how long must the lawyer wait before he can continue acting for this client?​
There is no provision in the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 prescribing a period during which a lawyer cannot act for a client after a STR has been filed on the client. STR filers may wish to conduct their business relationship with the client in accordance with their internal risk management policies and standards of prudence. 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 that STRO has disseminated the information to law enforcement agencies or foreign financial intelligence units, STRO may require more time to respond.
4. Can a law practice or a lawyer continue the relationship with the client after a STR has been filed on the client?​
The decision whether or not to continue the relationship with the client should depend on the internal risk management policies and standards of prudence of the law firm. A STR filer may decide to terminate the client relationship when the commercial or reputational risks are high. The lawyer should determine whether these circumstances, separately or together, provide reasonable grounds to suspect that the cash funds proffered by the client could be connected with criminal conduct. The lawyer should immediately file a STR if there is reason to suspect the funds is linked to criminal activity. The lawyer may then want to consider whether there is a commercial or reputational risk in continuing with the client relationship.
5. After a law practic​e or a lawyer files a STR, how does the lawyer tell the client that he cannot continue to represent him, without tipping off the client?
When a law practice or a lawyer decides to terminate the client relationship, they should not inform the client or any third party that a STR has been filed. This may constitute a tipping off, an offence under section 57 of the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992. The law practice or lawyer should give an appropriate reason to the client for terminating their relationship. The law firm could, for example, cite compliance requirements as a reason:
    • Risk Management or Compliance Department instructs to decline representation. We are unable to give details.
    • The matter did not accord with internal risk management policies and we are unable to give details.
6. Can the STR filer discharge his client without incurring liability under the ‘no-tipping off’ provision?​
When a law practice or a lawyer decides to terminate the client relationship, they should not inform the client or any third party that a STR has been filed. This may constitute a tipping off, an offence under section 57 of the CDSA. The law practice or lawyer should give an appropriate reason to the client for terminating their relationship. The law firm could, for example, cite compliance requirements as a reason:
    • Risk Management or Compliance Department instructs to decline representation. We are unable to give details.
    • The matter did not accord with internal risk management policies and we are unable to give details.
7. What kind of action can the STR filer take after the STR is filed?​
After a STR is filed with STRO, no further action is required of the STR filer. STR filers may wish to conduct their business relationship with the client in accordance with their internal risk management policies and standards of prudence. Where required, STRO may request for further information from STR filers.
8. 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.
9. 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.
National Risk Assessments ('NRAs')
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:
MAS Targeted Financial Sanctions and the Financial Action Task Force (‘FATF’)
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
AML / CFT E-Learning Course by the Law Society of Singapore
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.  
Additional Materials
 

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.

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