The bill aimed at lowering the threshold on cash deposits in Singapore’s casinos could be passed “within the next few months”, with “implementation to follow soon thereafter”, points out a top industry expert.

The new shift involves lowering the threshold to SG$4,000 ($2,950) from the previous SG$5,000 ($3,700), to be in line with Financial Action Task Force (FATF) standards.

While announcing that the measure would come into effect this year, authorities did not give a timeline.

Lau Kok Keng, Head of Intellectual Property, Sports & Gaming for Rajah & Tann Singapore, indicates that the new bill is just part of a raft of changes that Singapore has been implementing to ensure strict compliance with the FATF standards.

Singapore is currently compliant with 20 of the FATF’s recommendations, while being largely compliant on 17. It is still ‘partially compliant’ on three of the 40 overall recommendations.

A possible onsite assessment of the territory’s compliance with the FATF’s recommendations is scheduled for August of 2025, while its last evaluation was conducted in June of 2016.

Room for improvement

Lau Kok Keng indicates that, while ongoing changes are being made, “there is room for improvements in Singapore”.

“I think that Singapore has indeed been strengthening its policies steadily over the years. The recent measure is indicative of this, which is part of a refreshing of Singapore’s National Strategy for Countering the Financing of Terrorism first published in October 2022, comprising a five-pronged plan for greater coordination between law enforcement agencies and international counterparts”.

In addition to this, and after feedback from the FATF “and comments gathered through public consultation, a new legislation has also been introduced, namely the Corporate Service Providers Act, that was passed on July 2^nd, 2024,” he indicates.

Under the new bill “all registered corporate service providers are required to comply with anti-money laundering and countering the financing of terrorism obligations, and fines will be imposed for breaches of such obligations by registered corporate service providers and their senior management.”

But are the measures going far enough?

Lau indicates a few areas that could be more thoroughly explored.
“The use of artificial intelligence and machine learning in improving detection capabilities for suspicious transactions and enhancing compliance efficiencies, and limiting cash transactions and moving towards digital and cashless payments which may enhance the ability of casino operators to identify patrons and verify their source of wealth” are all possible areas which could see further change.

Immediate impact

These other changes will take time to implement, whereas the newly proposed measures to lower thresholds will have an immediate impact, once implemented.

“Lowering the threshold will almost certainly result in increased compliance costs for the casinos. This measure is also likely to impact patron experience in casinos, since patrons engaging in transactions at or above this lowered threshold will be subject to more stringent identification and verification processes, potentially resulting in longer wait times, increased scrutiny and frustration, leading to lower customer satisfaction,” indicates the expert.

But there is a silver lining

“The lowering of the threshold will result in a broader range of transactions that could potentially involve illicit funds being captured, thereby enhancing transparency and regulatory control over gambling industry, which is highly susceptible to AML risks.”

And it’s already been proven that the industry is susceptible to these risks. As recently as December of last year, Resorts World Sentosa was fined some SG$2.25 million ($1.7 million) for failing to conduct sufficient customer due diligence checks.

And further penalties could be on the horizon “if the two gaming operators fail to comply with regulatory requirements,” notes Lau.

“The Gambling Regulatory Authority (“GRA”) has consistently stated that it takes a serious view of such AML compliance lapses and will not hesitate to take disciplinary action against errant casino operators.”

Money laundering case

The timing of the new bill is interesting, as the Merlion city was “thrust into the spotlight” following the SG$3 billion ($2.22 billion) money laundering case involving 10 Chinese nationals “who have all since been convicted and sentenced”.

But it’s unlikely that the two are connected, indicates the expert.

“Work on the case had begun over two years ago, even before news about the money laundering probe broke in August last year. Hence, it cannot be said with certainty that there is any direct link between the two, although the money laundering case may have impacted the considerations leading up to these changes,” notes Lau.

In its Money Laundering Risk Assessment Report for 2024, the Monetary Authority of Singapore (MAS) indicated that Casinos were ranked as of ‘Medium High ML risk’, despite posing a less serious threat than Corporate Service Providers (CSPs) and the real estate sector.

However, the report does highlight that ‘we have not encountered any instance where the casinos were found to be directly complicit in ML activities in Singapore and have only observed a low number of cases where criminal proceeds were converted to casino chips for self-laundering purposes.’

Legal framework for money flows

But what are the laws currently affecting these money flows?

Lau Kok Keng breaks down the current regulations related to gambling activities.

“The Casino Control Act requires casino operators to engage in customer due diligence measures to detect and prevent money laundering and financing of terrorism, while the Casino Control (Prevention of Money Laundering and Terrorism Financing) Regulations sets out various AML obligations of the casinos, which include the identification and verification of the identity of the person making deposits in excess of S$5000 (soon to be reduced to S$4000), and the obligation to develop and implement a suspicious transaction reporting framework.

“Other laws such as the Terrorism (Suppressing of Financing) Act, Organised Crime Act 2015 and the Corruption, Drug Trafficking and other Serious Crimes (Confiscation of Benefits) Act allow for the seizure and forfeiture of benefits of crime.”