Environmental crimes, such as illegal wildlife trafficking and illegal logging, disrupt and harm our environment and eco-system with far-reaching and long-term impact for future generations. Such crimes are estimated to generate around US$110 billion to US$281 billion in criminal gains globally.
On 29 May 2024, the Monetary Authority of Singapore (“MAS“) published an Environmental Crimes Money Laundering National Risk Assessment (“NRA“), which:
(a) identifies the key threats and vulnerabilities in environmental crimes money laundering (“ECML“) that Singapore is exposed to; and
(b) outlines mitigation measures which government agencies, financial institutions (FIs) and Designated Non-Financial Businesses and Professionals (DNFBPs) can develop to address the risks.
Key findings of the NRA include:
(a) Singapore is a transit country for ECML. This stems from its geographical location along the Asian environmental goods supply routes, and its position as an international financial centre that may be used to facilitate illicit financing and trade flows.
(b) Singapore’s key ECML threats are assessed to be from illegal wildlife trade, illegal logging and waste trafficking. Such threats are commonly associated with trade-based money laundering.
(c) The sectors most exposed to ECML risks are banks and cross-border payment service providers. These sectors are more internationally oriented and are most vulnerable to being misused for ECML.
(d) Due to Singapore’s reasonably good level of controls, there is a medium-low risk of criminals using Singapore for ECML despite its exposure to ECML threats. Such controls include its strong and transparent legal and enforcement framework for the detection and investigation of money laundering crimes.
Click on the following links for more information (available on the MAS website at www.mas.gov.sg):
Disclaimer
Rajah & Tann Asia is a network of member firms with local legal practices in Cambodia, Indonesia, Lao PDR, Malaysia, Myanmar, the Philippines, Singapore, Thailand and Vietnam. Our Asian network also includes our regional office in China as well as regional desks focused on Brunei, Japan and South Asia. Member firms are independently constituted and regulated in accordance with relevant local requirements.
The contents of this publication are owned by Rajah & Tann Asia together with each of its member firms and are subject to all relevant protection (including but not limited to copyright protection) under the laws of each of the countries where the member firm operates and, through international treaties, other countries. No part of this publication may be reproduced, licensed, sold, published, transmitted, modified, adapted, publicly displayed, broadcast (including storage in any medium by electronic means whether or not transiently for any purpose save as permitted herein) without the prior written permission of Rajah & Tann Asia or its respective member firms.
Please note also that whilst the information in this publication is correct to the best of our knowledge and belief at the time of writing, it is only intended to provide a general guide to the subject matter and should not be treated as legal advice or a substitute for specific professional advice for any particular course of action as such information may not suit your specific business and operational requirements. You should seek legal advice for your specific situation. In addition, the information in this publication does not create any relationship, whether legally binding or otherwise. Rajah & Tann Asia and its member firms do not accept, and fully disclaim, responsibility for any loss or damage which may result from accessing or relying on the information in this publication.
