The threshold for performing due diligence checks on cash deposits in Singapore casinos is going to be lowered, according to the city-state’s authorities, amongst tighter controls on counter terrorism financing (CFT).
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.
The measure is set to come into effect this year, but no timeline has yet been indicated.
Only two casinos are allowed to operate in Singapore: Marina Bay Sands and Resorts World Sentosa.
A Monday joint statement by the Singapore’s Ministry of Home Affairs, Ministry of Finance and Monetary Authority indicate that ‘money remittances remain at High risk’, while ‘cross border cash movements remain at Medium-Low risk’ and ‘digital payment token service providers have been elevated from Medium-Low to Medium-High risk’.
An update from its 2020 guidelines, as outlined in the ‘National Strategy for Countering the Financing of Terrorism (NSCFT), indicates that customer due diligence (CDD) will be applied to ‘all financial transactions’ in the casino sector.
‘This adjustment aims to strengthen deterrence and prevent misuse of Singapore’s casinos for TF (terrorism financing) purposes’.
Regarding the FATF, the international body indicates that Singapore is compliant with 20 of the group’s 40 recommendations, largely compliant with 17 of them and partially compliant with three 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.
Unlike the Philippines, for example, Singapore is not on the FATF ‘grey list’ – subject to increased monitoring by the international oversight body.
Myanmar is currently on the FATF’s ‘black list’- notably a ‘high-risk jurisdiction subject to a call for action’. The list was updated in June of this year.
In line with the initiatives – spread across dozens of government agencies and departments, the group notes that it will be ‘Conducting enhanced surveillance and supervisory activities focused on higher TF risk areas and entities,’ as well as ‘engaging with the industry through outreach, guidance, and industry cooperation initiatives’.
Due diligence, STFs and money laundering
Among the focuses is DFNBPs (designated non-financial businesses and professions) which, under which casino operators are classified.
Aligning with the FATF standards, the authorities, according to the national strategy (NSCFT) means not only ‘identifying and verifying customers’, ‘conducting ongoing monitoring and regular customer due diligence’ (with enhanced measures for those deemed high risk’, ‘conducting screening to ensure compliance with CFT requirements’ and ‘promptly filing suspicious transaction reports’.
For casino operators in Singapore, STR reports are required before the end of each applicable reporting period involving ‘every cash transaction with a patron involving either cash in or cash out of SG$10,000 ($7,400) or more in a single transaction’.
This also applies to ‘multiple cash transactions which the casino operator knows are entered into by or on behalf of a patron’, of which the aggregate is cash in or cash out of SG$10,000 or more ‘in any gaming day’.
Failure to do so can result in a potential conviction to a fine of up to SG$20,000 ($14,800).
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.’
The MAS indicates that its investigative unit has ‘observed that the majority of STRs filed by casinos do not relate to potential ML offenses and instead involve a suspicion of offenses under the Casino Control Act or are filed pursuant to adverse news on casino patrons’.
The upcoming change to the threshold for cash deposits was highlighted in the assessment, published on June 20th of this year, which indicated (on page 112) that the Gaming Regulatory Authority (GRA) ‘will be imposing legislative amendments to lower the prescribed CDD threshold for casino transactions, and to align them with the FATF Standards’.
To ensure compliance of both AML and CFT measures, the GRA ‘will continue to perform risk-focused monitoring and inspections of the casino operators commensurate with the moderately higher risks presented by the sector’.
