The Monetary Authority of Singapore (MAS) announced its regulatory actions against nine financial institutions (FIs) and a number of individuals for anti-money laundering-related breaches.

Among the penalised banks, Credit Suisse Singapore Branch faced the highest fine of SGD5.8 million ($4.5 million), followed closely by United Overseas Bank Limited at SGD 5.6 million ($4.3 million). UBS AG’s Singapore branch was fined SGD 3 million ($2.3 million), while Citi—which includes Citibank N.A. Singapore and Citibank Singapore Limited—was fined a combined SGD 2.6 million ($2.03 million). Other penalised banks include Bank Julius Baer’s Singapore branch (SGD 2.4 million [$1.8 million]) and LGT Bank (Singapore) Ltd. (SGD 1 million [$783,824]).

In addition to banks, penalties were also issued to capital market and trust service providers. UOB Kay Hian Private Limited was fined SGD 2.85 million ($2.2 million), the highest among capital markets services licence holders, while Blue Ocean Invest Pte. Ltd. received a SGD 2.4 million ($1.8 million) penalty. Trident Trust Company (Singapore), a licensed trust company, was fined SGD 1.8 million ($1.4 million).

MAS has completed its supervisory examinations against pertinent FIs with nexus to persons of interest (POIs) in the major money laundering (ML) case of August 2023, and their employees who fell short of MAS’ Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) requirements. The present suite of actions marks the conclusion of MAS’ enforcement actions against FIs with material nexus to the major ML case.

Regulatory actions against financial institutions

MAS has imposed composition penalties amounting to SGD 27.45 million ($21.5 million) in total on nine FIs for breaches of MAS’ AML/CFT requirements in relation to the case.

The penalties took into account various factors including the extent of the FI’s exposure to the POIs, the number of breaches of MAS’ requirements, and the degree of weakness in the FI’s AML/CFT controls.

The breaches were identified during MAS’ supervisory examinations of the FIs from early 2023 to early 2025. Overall, MAS observed that most of the FIs had established AML/CFT policies and controls. The breaches arose out of poor or inconsistent implementation of these policies and controls. The FIs have embarked on remediation of the deficiencies and MAS will monitor their progress closely.

MAS found shortcomings in the areas of:

a) Customer risk assessment. Five of the FIs (BJBS, BOIPL, Citi, CSSB, UOBKH) failed to implement adequate policies or processes for the rating of ML risks presented by some of their customers. This led to mis-rating of ML risks and affected their ability to apply appropriate controls and address higher ML risks presented by several POIs.

(b) Establishing and corroborating source of wealth (SOW) of customers who posed a higher risk of ML. All nine FIs did not detect or adequately follow up on significant discrepancies or red flags noted in information and documents that should have cast doubt on some customers’ purported SOW and which indicated increased risk of ML. In some cases, there was no corroboration of significant aspects of SOW.

(c) Transaction monitoring. Eight FIs (BJBS, Citi, CSSB, LGTS, UOB, UOBKH, TTCSPL, UBSS) failed to adequately review relevant transactions flagged as suspicious by their own systems. The relevant transactions were unusually large, inconsistent with the customers’ profiles, or showed unusual patterns.

(d) Post-Suspicious Transaction Report (STR) follow-up. In relation to customers the FIs had filed STRs on, two FIs (UOB and UOBKH) failed to take adequate and timely risk mitigation measures, such as enhanced monitoring and reviewing their risk classification.

The composition penalty imposed on CSSB also takes into account its breaches of MAS’ AML/CFT requirements in the period November 2017 to October 2023 in relationto accounts maintained by CSSB on behalf of certain US customers.

In addition, MAS has taken actions against individuals who were involved in managing the FIs’ relationships with the POIs.

Prohibition orders

MAS has issued prohibition orders (POs) ranging from three to six years in duration to the following individuals:

(a) Tsao Chung-Yi, CEO and executive director (ED) ofBOIPL. Tsao was issued a six-year PO with effect from 1 August 2025;

(b) Wong Xuan Ling, chief operating officer (COO) of BOIPL. Wong was issued a five-year PO with effect from 1 August 2025;

(c) Hsia Lun Wei @Henry Hsia, ED and relationship manager (RM) of BOIPL. Hsia was issued a three-year PO with effect from 30 June 2025; and

(d) Deng Xixi, former RM of BOIPL. Deng was issued a three-year PO with effect from 30 June 2025.

Tsao and Wong had failed as senior managers to ensure that the AML/CFT policies and controls in BOIPL kept pace with significant growth in its business in the three years since the company was set up. They failed to develop and implement adequate policies and controls in multiple areas, such as SOW corroboration, customer risk assessment, customer name screening and ongoing reviews of customer due diligence (CDD) information. They also failed to ensure that BOIPL’s AML/CFT policies and controls were subjected to audit reviews. Tsao, Wong, Hsia and Deng also failed to raise red flags when they were aware of information that should raise suspicion and failed to perform enhanced CDD for multiple POIs.

For the duration of their POs, Tsao, Wong, Hsia and Deng are prohibited from carrying on any activity or business, or providing any service, the carrying on or provision of which is regulated or authorised by MAS, and from taking part, directly or indirectly, in the management of, or acting as a director, partner or manager of, any FI. They are also prohibited from becoming a substantial shareholder of any FI that is a corporation; and if they are already a substantial shareholder of a FI that is a corporation, from acquiring any interest in any voting share in the FI other than a voting share in which they already have an interest. Further, Tsao and Wong are prohibited from performing the function of risk management and control.

Reprimands

MAS has issued reprimands to the following individuals for multiple lapses:

(a) For failure to ensure TTCSPL’s compliance with MAS’ requirements:

(i) Sean Andrew Coughlan, managing director, ED and resident manager of TTCSPL;

(ii) Tan Ho Kiat, COO, ED and head of compliance of TTCSPL; and

iii) Kek Yen Leng, ED, head of trust administration, and resident manager of TTCSPL.

As senior managers of TTCSPL, Coughlan and Tan failed to ensure that TTCSPL’s policies provided sufficient practical guidance on how to establish customers’ SOW. Furthermore, Coughlan, Tan and Kek failed as members of TTCSPL’s New Business Committee to detect or adequately assess multiple deficiencies in customers’ SOW corroboration when approving the onboarding of higher risk customers.

(b) For failures to conduct or ensure proper due diligence or post-STR followup in respect of several POIs:

(i) Ang Sze Hee, Alvin, former team head of group retail privilege banking, UOB; and

(ii) Tan Sheng Rong, Leonard, former team head of group retail privilege banking, UOB.

Another nine RMs and RM supervisors were privately reprimanded for more limited lapses.

A reprimand is issued to an individual based on their misconduct at the material time. For the purpose of assessing an individual’s fitness and propriety for employment, a reprimand does not necessarily mean that the individual is currently unfit or improper.

MAS had reviewed the conduct of a larger number of employees of the FIs connected to the cases but did not find evidence of significant lapses by most of them.MAS may take action against a few remaining individuals, after the conclusion of ongoing court proceedings or investigations. FIs should adopt best practices and remain vigilant against ML/TF risks

MAS has published supervisory expectations regarding the controls that FIs should implement to address the key findings from our supervisory examinations related to this case. The banking industry has also published best practice papers on implementing these controls, particularly in the area of SOW corroboration. FIs should benchmark themselves against MAS’ supervisory expectations and industry best practices, and execute robust, reasonable and risk-proportionate defences against ML.

RMs and their supervisors are reminded that they are part of the first line of defence in FIs against ML/TF risks. They should exercise the necessary vigilance and be alert to material red flags when dealing with existing and prospective customers, including when reviewing information obtained from such customers as part of the CDD process. They should identify and escalate concerns internally where warranted, so that appropriate risk mitigation measures can be taken.

Ho Hern Shin, deputy managing director (financial supervision), MAS, said, “Like other major international financial centres, Singapore is exposed to money laundering risks. The vigilance of our financial institutions and their employees is critical in mitigating such risks. MAS will work closely with financial institutions to promote more consistent implementation of AML/CFT measures. Where there are serious failings by FIs and their employees, MAS will not hesitate to take firm action.

Redissminated by The Asian Banker