On May 6, the Financial Action Task Force (FATF) published Singapore’s mutual evaluation report (MER), jointly prepared with the Asia/Pacific Group on Money Laundering (APG). FATF is an intergovernmental body that sets global standards for combating money laundering and terrorist financing. The regional partner supports the assessment process in the Asia-Pacific region. At the national level, the key roles are played by the Monetary Authority of Singapore (MAS), the country’s financial mega-regulator, and the Gambling Regulatory Authority, which oversees the gambling sector.

Fraud tops the threat list

According to the report, the list of Singapore’s main money-laundering risks is as follows:

  • Fraud and cyber-enabled fraud linked to various deception schemes are identified as the largest threat.
  • Among the significant predicate offences generating “dirty money,” corruption, tax crimes, and illegal gambling are highlighted.

An open economy, a colossal volume of cross-border transactions, and its status as a regional financial and wealth management hub make Singapore something of a magnet for illicit capital. In the evaluators’ view, these very characteristics increase the likelihood that criminal proceeds from abroad will be brought in, integrated into the local economy, and disguised as legitimate financial transactions.

How “dirty money” enters through digital gateways

FATF is particularly concerned about how funds enter the financial system via cyber-enabled fraud schemes. Proceeds from scams are deposited into bank accounts, move through chains of transactions, and gradually obscure their criminal origin, taking on the appearance of ordinary transactions. This kind of disguise makes the timely detection of suspicious flows harder and requires regulators to continually enhance monitoring tools.

The rise of cyber-enabled fraud in the financial sector is largely fueled by the rapid expansion of online gambling. No-deposit bonuses, free spins, and other promotions draw large numbers of newcomers into the industry, who often don’t fully understand the platforms’ rules and terms. It is inexperienced players who most often become targets of fraud schemes: fake platforms mimic the interface of legitimate casinos, harvest payment details, and siphon funds through the very chains of transactions that FATF warns about. 

The Canadian market, for example, faced a wave of fake sites copying the branding of licensed operators. A Reddit user described how they tried to use a promotional offer and entered their card details on a clone of a well-known resource. Later, they found out that the original offer was posted in a no-deposit bonus roundup. And the site they landed on merely replicated its design. 

Such cases show that fraudsters exploit not so much technical vulnerabilities as the trustfulness of an audience unfamiliar with licensing checks and wagering requirements. That is why regulators increasingly insist on improving users’ digital literacy as one of the key barriers to laundering funds through the gambling sector.

Another major contributor to the overall risk picture is the cross-border dimension. As the report emphasises, a significant share of crimes is committed outside Singapore, and the country is used as a transit point or final destination for laundering. Among the issues mentioned, cross-border organised crime and illegal gambling operations deliberately targeting Singapore’s jurisdiction are singled out in particular.

Casinos under tight regulatory scrutiny

Against the backdrop of broad risks, oversight of the legal gambling sector received a positive assessment from FATF. The Gambling Regulatory Authority, according to the experts’ conclusions, demonstrates a strong understanding of AML/CFT risks and closely oversees the two integrated resort operators: Marina Bay Sands and Resorts World Sentosa. The casinos themselves have implemented a set of measures:

  • Customer identification procedures and customer due diligence (CDD) (due diligence checks);
  • Ongoing transaction monitoring;
  • Detecting suspicious activity and reporting it.

Between 2020 and 2024, 16 inspections were conducted covering CDD, ongoing monitoring, and suspicious transaction reporting. As a result, 9 warnings were issued and 6 fines were imposed totaling almost SG$2.7 million (≈$2.1 million). Nevertheless, FATF noted that despite strict oversight of the casinos themselves, vulnerabilities linked to actors and channels outside the gambling industry remain.

A S$3 billion case as a reflection of the problem

To illustrate the scale of the threat, the report refers to a 2023 investigation in which illegal assets totalling SG$3 billion (≈$2.3 billion) were uncovered. The authorities confiscated luxury real estate, cars, cash, cryptoassets, and other property belonging to foreign individuals implicated in the case.

Over the past five years, Singapore has conducted more than 11,000 money-laundering investigations, with over 80% of them initiated following reports from victims of cyber-enabled fraud. 682 cases proceeded to prosecution. Cases related to tax crimes, trade-based laundering (laundering through trade operations), and more complex financial schemes are presented in the report as less prevalent relative to the country’s overall risk profile.

Seven out of eleven at the highest level

Following the evaluation, Singapore was rated Substantial Effectiveness on 7 of 11 key areas (Immediate Outcomes) and Moderate Effectiveness on the remaining 4. The country was moved to FATF’s regular follow-up process, an improvement compared with the enhanced follow-up applied after the 2016 evaluation.

In an official statement, the Monetary Authority of Singapore said that the report’s findings confirm the country has a strong system for combating financial crime.