Singapore is set to implement significant changes to its casino regulations aimed at strengthening anti-money laundering (AML) and combatting the financing of terrorism (CFT) measures. The updates include lowering the threshold for customer due diligence checks and introducing new scrutiny for weapons finance. These measures will ensure that Singapore’s casino sector aligns with international standards set by the Financial Action Task Force (FATF).

Lowering the Due Diligence Threshold

The Gambling Regulatory Authority (GRA) of Singapore has announced a reduction in the cash deposit amount that triggers customer due diligence checks. Currently, this threshold is set at SGD5,000 (approximately USD3,685). However, the new regulations will lower this amount to SGD4,000 (approximately USD2,950). This change is expected to be implemented within the year, although the exact date has yet to be specified.

According to the updated Money Laundering National Risk Assessment, this reduction aims to enhance the casino sector’s AML/CFT regime. T. Raja Kumar, former president of the FATF and the inaugural chief executive of the Casino Regulatory Authority, emphasized the importance of aligning Singapore’s regulations with international standards.

Introduction of Weapons Finance Scrutiny

In addition to lowering the due diligence threshold, Singapore is also introducing new measures to address proliferation financing. This term, defined by the FATF, refers to funds or financial services used for nuclear, chemical, or biological weapons in violation of national laws or international obligations.

The proposed Anti-Money Laundering and Other Matters Bill, currently under review by Singapore’s parliament, includes provisions to tighten casino operators’ requirements for due diligence on the source of player funds. The bill will mandate that casino operators consider proliferation financing risks during customer due diligence checks. The Gambling Regulatory Authority of Singapore will be empowered to issue regulations to detect or prevent proliferation financing.

Enhanced Monitoring and Compliance

The Ministry of Home Affairs noted that the new regulations would require casino operators to conduct due diligence on patrons for any single cash transaction involving SGD10,000 (approximately USD7,371) or more, or when receiving SGD4,000 (approximately USD2,950) or more in a single transaction for deposit into a customer account.

Despite the moderately high risk of money laundering in Singapore’s casinos, the Money Laundering Risk Assessment Report Singapore 2024 reported no direct complicity by casinos in money laundering activities. However, there have been cases of third-party money laundering facilitated by casinos. One case involved an alleged conspiracy to cheat vessel owners of undelivered fuel, with proceeds amounting to about SGD1.9 million used to purchase casino chips.

Easing the Burden of Proof

The Anti-Money Laundering and Other Matters Bill also aims to ease the burden of proof in money laundering prosecutions. The amendment to the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act will mean that prosecutors no longer need to show a direct link between criminal conduct and laundered money. It will be sufficient to prove that the money launderer knew or had reasonable grounds to believe they were dealing with criminal proceeds.

This change is designed to facilitate the prosecution of money mules, especially in cases where laundered money has passed through multiple bank accounts and intermediaries in foreign jurisdictions before entering Singapore.

Conclusion

Singapore’s enhanced regulations represent a significant step towards strengthening its AML/CFT regime within the casino sector. Singapore is aligning itself more closely with international standards by lowering due diligence thresholds and introducing new measures to combat proliferation financing. These changes underscore the city-state’s commitment to maintaining a robust and effective regulatory framework to combat financial crimes.

Sources:

Weapons finance scrutiny to be part of Singapore casino AML, ggrasia.com, July 1, 2024.

Singapore to cut casino diligence trigger to US$2,950: media, ggrasia.com, July 3, 2024.

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