Singapore is poised to pass a bill that will lower the threshold for cash deposits in its casinos, according to a top industry expert cited by Asia Gaming Brief. This legislative move, anticipated to be approved “within the next few months” with implementation to follow shortly after, aims to align with Financial Action Task Force (FATF) standards by reducing the threshold from SG$5,000 ($3,700) to SG$4,000 ($2,950).
Lau Kok Keng, Head of Intellectual Property, Sports & Gaming at Rajah & Tann Singapore, explained that this bill is part of a series of measures Singapore has been adopting to ensure adherence to FATF standards. Singapore is currently compliant with 20 of the FATF’s recommendations and largely compliant with 17. However, it remains partially compliant with three of the 40 overall recommendations.
Singapore’s commitment to enhancing its anti-money laundering (AML) framework is evident as it prepares for an onsite FATF compliance assessment scheduled for August 2025, following its last evaluation in June 2016.
Ongoing Policy Strengthening
Lau highlighted that while Singapore has made significant strides, there is always room for improvement. “Singapore has indeed been strengthening its policies steadily over the years. The recent measure is indicative of this, part of a refreshing of Singapore’s National Strategy for Countering the Financing of Terrorism, first published in October 2022. This strategy includes a five-pronged plan for greater coordination between law enforcement agencies and international counterparts,” Lau states.
Additionally, Singapore has introduced new legislation following FATF feedback and public consultations. The Corporate Service Providers Act passed on July 2, 2024, mandates that all registered corporate service providers comply with AML and countering the financing of terrorism (CFT) obligations. Violations of these obligations by corporate service providers and their senior management will result in fines.
Despite these measures, Lau identifies areas where further improvements can be made. “The use of artificial intelligence and machine learning in improving detection capabilities for suspicious transactions and enhancing compliance efficiencies, as well as limiting cash transactions and moving towards digital and cashless payments, may enhance the ability of casino operators to identify patrons and verify their source of wealth,” he suggested.
These advancements will require time to implement, but the immediate impact of lowering the deposit threshold will be significant. “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, as 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,” noted Lau.
Increased Transparency and Control
However, there is a bright side. “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 the gambling industry, which is highly susceptible to AML risks,” Lau explains.
Recent incidents underscore the industry’s susceptibility to AML risks. In December last year, Resorts World Sentosa was fined SG$2.25 million ($1.7 million) for inadequate customer due diligence checks. Lau warns that further penalties could follow if gaming operators fail to comply with regulatory requirements. “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,” he adds.
The timing of this bill is noteworthy, coinciding with the aftermath of a major money laundering case in Singapore involving SG$3 billion ($2.22 billion) and ten Chinese nationals. However, Lau clarifies that the bill is not a direct response to this case. “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,” he notes.
The Monetary Authority of Singapore (MAS) in its 2024 Money Laundering Risk Assessment Report ranked casinos as having a ‘Medium High ML risk’. However, the report also highlighted that casinos were not found to be directly complicit in money laundering activities in Singapore, with only a few cases of criminal proceeds being converted to casino chips for self-laundering purposes.
Current Regulations and Future Directions
Lau outlined the current regulations governing money flows in 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 for casinos, including the identification and verification of the identity of individuals making deposits in excess of SG$5,000 (soon to be SG$4,000), and the obligation to develop and implement a suspicious transaction reporting framework,” he explains.
Additionally, laws such as the Terrorism (Suppression of Financing) Act, Organised Crime Act 2015, and the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act facilitate the seizure and forfeiture of crime benefits.
In conclusion, the new bill lowering the casino deposit threshold in Singapore is a significant step toward enhancing regulatory compliance and transparency in the gambling sector. While it may pose challenges regarding increased compliance costs and potential impacts on patron experience, it aims to ultimately fortify the industry’s defenses against money laundering and financial crimes.
