About the Report

Similar to the experience in other jurisdictions, legal arrangements are not as frequently exploited by bad actors as legal persons (e.g. companies) in Singapore. In cases where legal arrangements are misused for ML, they are often part of a broader complex structure involving companies, which may span multiple jurisdictions. Legal arrangements are also generally used for a wide variety of legitimate purposes.  However, there remains a risk that they may be misused by bad actors to conceal the beneficial ownership of illicit assets.

As such, the relevant law enforcement agencies, financial intelligence unit, and policy and supervisory agencies will continue to stay vigilant of the risks identified and raise the private sector’s risks awareness. Financial institutions and designated non-financial businesses and professionals (such as banks, trust companies and lawyers etc.) should also take reference from the LARA in assessing their ML and TF risks and enhance their controls where appropriate.