Anti-Money Laundering and other Matters Act 2024 – What you need to know

Anti-Money Laundering and other Matters Act 2024 – What you need to know

In November 2024, the Singapore’s Ministry of Home Affairs announced the phased commencement of the Anti-Money Laundering and Other Matters Act 2024 (“AMLOMA”). Some provisions have come into force since 14 November 2024, while others will only commence on a date to be notified by the Minister. 

Here’s what you need to know. 

We highlight three major enhancements that the AMLOMA brings to Singapore’s anti-money laundering regime:

1. Lower Evidentiary Threshold for money laundering offences – it is now easier for law enforcement agencies to pursue and prosecute cross-border money laundering of proceeds of overseas criminal conduct in Singapore. 
2. Foreign environmental crimes are now predicate offences for money laundering, when they previously were not.
3. Enhanced powers for authorities to deal with seized properties of “absconded” suspects – i.e. persons suspected of having committed serious crimes, who do not personally come to Singapore to assist with investigations.

Which provisions have come into force?

1. Making prosecution of money laundering offences easier

Prosecutors will no longer be required to show the complete trail of criminal proceeds, from when the crime was committed, to when the money was eventually deposited with the money launderer. For certain offences, it would be sufficient for the Prosecution to prove that the money launderer knew or had reasonable grounds to believe that he was dealing with criminal proceeds.

Practical impact:

• This significantly widens the scope of liability for money laundering, under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 (“CDSA”).
• The Prosecution will only have to prove that a person / entity has reasonable grounds to believe that they are dealing with criminal proceeds. It no longer needs to show the complete trail of money from the victim to the money launderer, to prove that the money is in fact the benefits from criminal conduct. 
• The burden has been shifted to the accused – the accused may be acquitted if he or she can raise a reasonable doubt as to whether the money laundered in Singapore was in fact benefits from criminal conduct.¹
• This is a legislative amendment to the existing position in law as set out in Ang Jeanette v Public Prosecutor [2011] 4 SLR 1.² 

2. New predicate offences for money laundering

Serious environmental crimes committed overseas are now designated in the Third Schedule of the CDSA as “foreign serious environmental offences” and included in the list of predicate offences for money laundering. 

Practical impact:

• This development significantly expands the scope of predicate offences for money laundering in Singapore. 
• Environmental crimes committed overseas (such as illegal logging, wildlife trafficking, and unlicensed mining) may now trigger anti-money laundering (AML) reporting obligations if linked to funds or assets transacted through Singapore.
• This legal development is a recognition that environmental crimes are one of the largest contributors to transnational organized criminal activities in East Asia and Pacific region, which leads to heightened risks for money laundering in Singapore, as an international financial, trading and transit hub.  
• Companies operating or investing in high-risk jurisdictions in the relevant regions, especially in forestry, agriculture, commodities, or natural resources, should reassess their due diligence procedures, enhance screening measures, and be alert to red flags involving environmental crimes. Firms may also wish to review relationships with counterparties or clients engaged in activities with known environmental compliance concerns.

3. Dealing with seized property of “absconded” suspects in money laundering investigations

In the course of investigations, law enforcement agencies may seize properties linked to persons who are suspected of having committed offences under Singapore’s laws and cannot be found, apprehended or extradited at the end of 6 months from the date on which investigations against that person commenced (i.e. an “absconded person”). Investigations can be willfully stalled by such absconded persons if they decide not to cooperate with investigations.

The law on disposal of property has been amended to now require an “absconded person”, who is suspected of having committed an arrestable offence or serious offences under the CDSA, to personally present himself or herself before a law enforcement officer to assist in investigations, before he or she may make a claim to the seized property. 

Practical impact:

• Overseas suspects cannot assert any claim over seized property, unless they personally come to Singapore to assist in police investigations (e.g. give a police statement).
• Appointing a Singapore lawyer alone will no longer be sufficient. Legal representation cannot substitute for the suspect’s personal cooperation with law enforcement. As such, attempts to reclaim seized assets through disposal proceedings in Singapore Courts may fail unless the suspect physically returns to Singapore.
• These amendments are particularly relevant for individuals and entities with cross-border operations or foreign directors/shareholders. Clients should be aware of the strategic and legal risks of absconding or remaining overseas when subject to investigation, as it may result in permanent loss of assets seized in Singapore.

Which are the provisions that will come into force on a later date? 

There are certain amendments made by the AMLOMA, not yet in force, to empower the Court to order the sale of restrained and seized property in situations where:

• The asset is likely to depreciate in value,  
• The asset is dangerous, unduly costly or impractical to store or maintain, or
• All parties known to have a prima facie interest in the property consent to the sale.

Practical impact (once the provisions come into force):

• Once seized, these types of assets may be liquidated by the authorities even without the owner’s consent, especially where upkeep is costly or practical constraints arise. For companies, these presents risks in the following areas:
  • Loss of control over how and when assets are disposed of, and
  • Forced liquidation at potentially depressed market prices.
     
• Firms must prepare for the possibility that assets could be sold before legal proceedings conclude. This risk is more pronounced for sectors involving high-value movable or volatile assets. For example:
  • Vehicles, vessels or machinery/equipment that may degrade without maintenance, or where berthing and upkeep costs are substantial. 
  • Cargo that is perishable or where warehousing fees quickly accrue (e.g. oil, grain, metal ore, chemicals etc).
  • Cryptocurrencies and digital tokens, where values fluctuate dramatically and custodial risks (e.g. loss of access keys, fraud, or hacking) complicate long-term seizure or management.

Trend on imposing Customer Due Diligence measures on organisations

As Singapore continues to ramp up its AML enforcement efforts, there is a growing trend towards imposing stricter customer due diligence (CDD) obligations on organisations across various sectors. 

• Though the AMLOMA, tighter restrictions have been imposed on casino operators to detect and prevent money laundering, terrorism financing and proliferation financing, and lowering the threshold for CDD checks on patrons. 
• A similar regulatory tightening is also seen in the new Corporate Service Providers Act 2024 and Corporate Service Providers Regulations 2025, which came into effect in Singapore on 9 June 2025, and impose robust anti-money laundering, counter financing of terrorism and counter proliferation financing (AML/CFT/CPF) obligations on corporate service providers. See our related article: “New CSP Regulatory Framework – Raising the Bar on AML Compliance”.

¹See Anti-Money Laundering and Other Matters Bill Explanatory Statement, regarding Clause 11.

²Where the High Court held that in order to prove an offence under section 51(1)(a) of the CDSA (previously numbered as section 44(1)(a)), the prosecution had to establish that the moneys involved were in fact the benefits from criminal conduct.