Singapore – Corporate Crime Update

  • Legal Development 25 March 2024 25 March 2024
  • Asia Pacific

  • Regulatory & Investigations

A summary of recent developments on the topic of corporate crime in Singapore.

Seatrium Limited

On 31 May 2023, the Corrupt Practices Investigation Bureau (“CPIB”) announced the commencement of investigations into Seatrium Limited (formerly known as Sembcorp Marine) and individuals from Seatrium Limited relating to alleged offences that occurred in Brazil. This comes on the heels of Sembcorp Marine’s announcement in March 2023, that a wholly-owned Brazilian subsidiary, Estaleiro Jurong Aracruz, was being investigated by Brazil’s Comptroller General of the Union, in connection with conduct linked to Operation Car Wash. On 26 February 2024, Seatrium Limited announced an in-principle settlement agreement with the Brazilian authorities in relation to its Operation Car Wash investigations, which included a settlement payment of R$670,699,731.73 (equivalent to approximately S$182.4 million).

Citibank N.A., DBS Bank Ltd, OCBC Singapore, Swiss Life (Singapore)

On 21 June 2023, the Monetary Authority of Singapore (“MAS”) imposed composition penalties totalling S$3.8 million on Citibank N.A., Singapore Branch, DBS Bank Ltd, OCBC Singapore, and Swiss Life (Singapore) Pte. Ltd. The penalties were imposed for breaches of MAS’s Anti-Money Laundering and Countering the Financing of Terrorism requirements, in connection with their dealings with persons who were involved in or had links to transactions with Wirecard AG or its related parties.

Singapore police raids

On 15 August 2023, the Singapore police conducted simultaneous raids at multiple locations across the country, which resulted in the arrest of ten individuals for their suspected involvement in offences including money laundering and forgery, and the seizure or freezing of about S$1 billion in assets. Investigations are still ongoing and as of 19 January 2024, the total value of assets seized or issued with prohibition of disposal orders by the police stands at more than S$3 billion.

MAS Enforcement Report 2022/2023

In its Enforcement Report 2022/2023, released on 19 September 2023, a number of areas of focus were identified by MAS. These are market abuse, financial services misconduct, money laundering-related control breaches. Looking ahead into 2023/2024, the regulator has identified two additional areas of focus: enforcement in the digital asset ecosystem; and continued focus on asset and wealth managers.

S. Iswaran corruption charges

Following an investigation that began in July 2023, ex-Singapore cabinet minister S. Iswaran was, on 18 January 2024, charged with 27 offences, including corruption and obtaining gratification as a public servant. The alleged offences largely relate to his dealings as a Minister of the Government of Singapore with billionaire Ong Beng Seng, and his purported receipt of gratification in excess of S$384,000 from the latter in return for advancing his business interests. 

2024 AML measures

The Singapore Government is looking to table several new measures in early 2024, to strengthen the effectiveness of Singapore’s anti-money laundering regime. These include enhancing penalties on errant corporate service providers that breach their anti-money laundering and countering the financing of terrorism obligations, restricting the number of nominee directorships an individual can hold, implementing requirements to ensure that nominee directors are fit and proper to take up the role, and requiring nominee directors and shareholders to disclose their nominee status and the identity of their nominators to the regulator.

If you have any questions about the developments or this article, please contact Weiyi Tan or your usual contact at Clyde & Co. 


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