If you are developing a housing project or non-residential project with more than 4 units, you will have to comply with the anti-money laundering and terrorism financing provisions under the Housing Developers (Control & Licensing) Act, Sale of Commercial Properties Act and the Rules.
You will have to comply with the legislative requirements, such as:
i. implement programmes and measures to prevent money laundering and terrorism financing, in relation to the developer’s business of undertaking property development in Singapore; ii. notify purchasers of the documents and information that the developer must obtain to perform the customer due diligence measures, in the prescribed form, as required under rule 10(4)(aa) of the Housing Developers Rules and rule 5(4)(c) of the Sale of Commercial Properties Rules;
iii. perform appropriate Customer Due Diligence checks on new and existing property purchasers based on their risk profiles, with proper records and documentation; iv. screen property purchasers against the lists of terrorists, terrorist entities and designated individuals, as required under the Terrorism (Suppression of Financing) Act 2002 and the United Nations Act 2001; and v. submit a Suspicious Transaction Report to the Suspicious Transaction Reporting Office of the Commercial Affairs Department, for suspicions of money laundering or terrorism financing activities.
Under Section 45(1) of the CDSA, it is mandatory for a person to lodge a Suspicious Transaction Report with the Suspicious Transaction Reporting Office when, in the course of his trade, profession, business or employment, he knows or has reason to suspect that any property, directly or indirectly, represents proceeds of drug dealing or criminal conduct or was used/is intended to be used in connection with drug dealing or criminal conduct.
Find out more information on CDSA.
All persons shall not provide, use, possess or collect property, or make available any financial or other related services if they know or have reasonable grounds to believe that such property or services are to be used for terrorist acts or purposes, or to benefit any terrorist or terrorist entity; and
All persons shall not deal in any terrorist’s property. This includes entering into or facilitating any financial transaction relating to a dealing in such property, or providing any financial services or any other related services in respect of such property, knowing or having reasonable grounds to believe that the property is owned or controlled by or on behalf of any terrorist or terrorist entity, including funds derived or generated from property owned or controlled by any terrorist or terrorist entity.
Find out more information on TSOFA.
There are prohibitions against dealing, directly or indirectly, in any property owned or controlled by or on behalf of
These designated person are subject to travel ban and asset freeze due to their involvement in proliferation of weapons of mass destruction and its financing.
You are required to screen prospective purchasers against publicly available lists before the issue of any Option to Purchase.
Find out more information on the United Nations Act.
Under the UN Regulation:
To ensure compliance with the CDSA, TSOFA and the United Nations Act, before the issue of any Option to Purchase, developers should screen their prospective purchasers against the following publicly available lists of individuals and entities:
Developers are encouraged to refer and subscribe to the websites below for updates:
Examples of suspicious real estate transactions
Suspicious Transaction Reporting
Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act
Terrorism (Suppression of Financing) Act
Regulations under the United Nations Act