Clamping Down on Real Estate Shenanigans
Mr Speaker, the Bill at hand is focused on bringing into effect the recommendations of the Inter-Ministerial Committee (IMC) on Anti-Money Laundering (AML),[1] and in particular, those that relate to AML efforts in the real estate sector.
Improving the regulatory framework is critical, not least because the so-called Fujian Gang had parked a significant amount of their $3 billion in illicit funds in property.[2] This is unsurprising, given the big-ticket nature of real transactions (and the sky-high prices of our housing). But it just underscores the importance of enhancing our regulatory efforts in the sector, to prevent a recurrence of the events of August 2023. For this reason, there is little reason to reject legislative changes that edify such efforts, and hence I support the bill.
The Bill appears to only make marginal changes to the law
Given the importance of the issue, I was therefore surprised to see how the proposed amendments did not appear to be extensive. Many of them entail logical but seemingly-minor expansions of scope: from “money laundering and terrorism financing” to “money laundering, proliferation financing, and terrorism financing”.[3] Indeed, by my count, half of the clauses relate to this change.
While I do not necessarily question the value of enfolding the illicit financing of weapons of mass destruction (WMD)[4] into the scope of our anti-money laundering regime, it would nevertheless be helpful for this House to understand why this definitional expansion is deemed to be so crucial and relevant for our continued efforts in the real estate sector. How many of the recent cases that has come under investigation have involved the financing of WMDs, relative to AML or terrorism financing?
Based on my reading, the remaining provisions introduced are fairly mild: changing penalties to each instance of contravention,[5] adding a requirement that unrepresented counterparties in real estate transactions be subject to more scrutiny,[6] and raising the maximum penalty from $100,000 to $200,000.[7]
It is only in Clause 10 where there seems to be some real teeth: it proposes amendments to the regulation-making powers of the Council in Section 72 of the Estate Agents Act. But when one returns to the original Act, one may be disappointed again; here, the change once again seems to be to insert “proliferation financing” into the list of requirements for what may be subject to regulation.
The law is already sufficient, it is about enforcement
Perhaps the underlying reason for the seemingly-limited slate of amendments to the law is because there has already been a robust set of laws in place for proper due diligence of real estate transactions, even back in 2023. The Council for Estate Agencies, in its guide on 2021 regulations related to the prevention of money laundering and terrorism financing,[8] had already set out a comprehensive set of guidelines for how to conduct customer due diligence, including enhanced procedures for when risks of money laundering or terrorism financing is greater.
The January2025 version of the guide does update the list of red flag indicators, doubling the page coverage in process[9]—but my point is simply that we were not bereft of laws to combat so-called Singapore washing, even before this update.
The government has acknowledged as much. In a response to a Parliamentary Question posed by my honorable friend, Leong Mun Wai, the Minister for National Development indicated that, “property agencies and property agents are required to perform due diligence checks on their clients before commencing any business relationship or facilitating transaction with them”.[10]
Yet in our conversations with those working in the sector, some have shared a nagging sense that AML procedures in the industry are not as robust as those for the financial sector, more generally. The IMC report (p. 14) observed this, too, noting the “uneven implementation practices across and within sectors.” And in response to this clarification question that I had posed during the Ministerial Statement on the IMC last year, Minister Indranee conceded that the government “had already started to do more in this space… [and] will certainly see what [they]can do to strengthen the regulations in this sector”.[11]
The relevant question, beyond whether these changes proposed in today’s Bill are only marginal, is whether more substantive legislation is actually required to bring the industry to the frontier of AML best practices that the rest of the financial sector in Singapore is required to abide by. I am not a lawyer, but I would appreciate if the Minister would be willing to share if the laws, as they stand—together with the amendments proposed today—are indeed sufficient to have brought about an earlier detection and detention of the Fujian gang? If so, was it a matter of execution that fell short, rather than the legal framework, per se? And if not, what laws would be necessary, and why have these not been proposed to this House today?
Conclusion
The essence of my message, Sir, is simple: I do not believe that we actually lack the laws necessary to investigate, apprehend, and prosecute egregious money laundering practices in the real estate sector. What I feel is more important is a more steely-eyed focus on ensuring enforcement and compliance, for which I hope the government will redouble their efforts, to stamp out the scourge of Singapore-washing.
[1] Inter-Ministerial Committee on Ant-Money Laundering (2024),Proactive Prevention, Timely Detection, Effective Enforcement, Singapore: Ministry of Home Affairs, Ministry of Finance, and Monetary Authority of Singapore.
[2] Wong, S. & D. Sun (2023),“About $1b in Cash, Assets Seized and Frozen in One of S’pore’s Biggest Anti-Money Laundering Operations,” Straits Times, Aug 16.
[3] Clauses 2–5, 10, 12, 14–15, 17.
[4] Based on the definition in Sec. 2(b).
[5] Clauses 8–9.
[6] Clauses 6–7.
[7] Clause 16.
[8] CEA (2025),Guide on Estate Agents (Prevention of Money Laundering and Financing of Terrorism) Regulations 2021, ver. 18 Mar 2022, Singapore: Council for Estate Agencies.
[9] This is in Annex C, which was a 2-page “List of Common Suspicious Indicators” in the 2022 version of the guide, compared to a 4-page “List of Red Flag Indicators” in the 2025 version.
[10] Hansard 95(115):Nov 6.
[11] Hansard 95(113):Oct 3.
