SINGAPORE’S ANTI-MONEY LAUNDERING DILEMMA: CASE OF SMALL

STATE ECONOMIC SECURITY

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 STRATEGI
JOURNAL OF STRATEGIC STUDIES AND INTERNATIONAL RELATIONS
Lt Col Sharuddin bin Mohd Noh

system. INCSR (2016) has suggested that Singapore must include all types of financial
institutions and DNFBPs measures as it will allow more comprehensive measures and ability
to track significant financial movements in case of money laundering activity about to took
place.

The shortfall of its system as indicated by FATF MER, The Basel AML Index and
INSCR has raised concerned by SingaporeÕsauthorities. A joint media release by Home of
Ministry Affairs, Ministry of Finance (MOF) and MAS, acknowledging the shortfall and has
outlined the necessary action plan to be undertaken signify their willingness to respond to
international needs and clear indication that external perception over the country effort is very
significant. Since 2016, Singapore has tightened the reins particularly in efficiency measures
that include of shutting down of bank (case of BSI and Falcon), charging individual for multiple
breaches of AML/CFT law, and recent announced of setting up two new departments and a
dedicated Supervisory Team to enhance its supervisory focus (Nathan 2017). This
determination indicates how Singapore is attempting to lower down the probability of
damaging effect that money laundering may bring into their economic sphere, either in the
form of economy disruption or reputational concern. Describe by Deputy Prime Minster Teo,
when addressing the Institute of Singapore Charted AccountsÕFinancial Forensic Conference
2017 says that Òto tackle this (transnational crime and money laundering), the government and
private must work together to make sure that we are trusted hub, and that any illegal activities
are ferreted outÓ (Channel News Asia 2017).

DOMESTIC FACTORS INFLUENCE TOWARDS SINGAPOREÕS AML/CFT

SYSTEM EFFECTIVENESS AND COMPLIANCES

Singapore generally has demonstrated a strong achievement in emplacing its AML/CFT system
as indicated in their action plan. Nevertheless, The Basel AML Index 2016 on the other hand
identified SingaporeÕs significant weakness being in the area of effectiveness during the
implementation phase of the system. Therefore, this study further explored into the assessment
done by FATF MER 2016 and confirmed the level of effectiveness in SingaporeÕsAML/CFT
system which was in question. MER 2016 clearly indicated that SingaporeÕs AML/CFT system
effectiveness level does require substantial work. Supported by The Basel AML Index press
statement subsequently concluded that FATF MER 2016 report on Singapore AML/CFT

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 SINGAPOREÕSANTI-MONEY LAUNDERING DILEMMA: CASE OF SMALL STATE
ECONOMIC SECURITY STRATEGI
JOURNAL OF STRATEGIC STUDIES AND INTERNATIONAL RELATIONS

To understand the significance impact of money laundering towards the

macroeconomics of a country it is necessary to show it in the form of sums (Quirk 1997).
Between 2008 and 2014, SingaporeÕsLEAs managed to abstract less than 1 percent of illegal
proceeds compare to its amount of GDP. Presented in Table 4 and Table 5 respectively, amount
of proceeds involved in Singapore money laundering was not that significant when compared
with the size of its economy. Raise the question of effectiveness in implementing its AML/CFT
system.

Quirk (1997) when describing the amount of underground economy stated that the
amount will vary according to the size of economy. He then provides an example, like
Australia, the ground economy is estimated at 4-12 percent, Germany at 2-11 percent, Italy at
10-33 percent, Japan at 4-15 percent, the United Kingdom at 1-15 percent and the United States
at 4-33 percent. Quirk work is very much in used when referring to the magnitude of money
laundering within one country. Singapore in this instances has witnessed the amount of less
than 1 percent in money laundering proceeds based on data of seizure and confiscation of
criminal proceeds. Should this mean Singapore effectiveness in their effort to combat money
laundering is still far from being a success or is it because their understanding on compliances
towards the system they had in place is very low? Since MER (2016) and The Basel AML
Index has assessed Singapore effectiveness in money laundering investigation, prosecution and
confiscation at a moderate level, thus answer to the effectiveness is more appropriate rather
than confirming its successes on denying money laundering activity.

Table 4: Seizure by Act (in SGD)

Act 2011 2012 2013 2014 Total

CPC 70,800,000 42,200,00 122,500,000 68,000,000 303,500,000
Customs Act 2,200,000 2,070,000 2,010,000 2,500,000 8,780,000
Immigration Act 0 100,000 100,000 100,000 300,000
MDA 450,000 730,000 680,000 490,000 2,350,000
PCA 500,000 800,000 240,000 0 1,540,000
CDSA 23,000,000 2,300,000 0 0 25,300,000
Total 96,950,000 48,200,000 125,530,000 71,090,000 341,770,000

Source: Singapore MER 2016, 18 February 2017

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 Dr Andrew Kam Jia Yi is an Associate Professor/Senior Research Fellow at Institute of
Malaysia and International Studies (IKMAS) National University of Malaysia (UKM). Dr
Andrew Kam Jia Yi graduated First Class in BSc. Economics specializing in Econometrics
at the UKM, MSc Economics from Warwick University, United Kingdom and PhD from
the Australia National University (ANU). His research interest include international trade,
industrialization and economic growth. He was the recipient of the Chevening Scholarship in
2005, Australian Endeavour Postgraduate in 2008 and also the recipient of 2014-2015 Malaysia
Fulbright Scholar Program.
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