MAS Takes Regulatory Actions against 9 Financial Institutions for Anti-Money Laundering Related Breaches

Singapore, 4 July 2025… The Monetary Authority of Singapore (MAS) announced today its regulatory actions against nine financial institutions (FIs) and a number of individuals for anti-money laundering related breaches. MAS has completed its supervisory examinations against pertinent FIs with nexus to persons of interest (POIs) in the major money laundering (ML) case of August 2023, and their employees who fell short of MAS' Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) requirements. The present suite of actions marks the conclusion of MAS' enforcement actions against FIs with material nexus to the major ML case.

Regulatory actions against financial institutions

2 MAS has imposed composition penalties amounting to S$27.45 million in total on nine FIs for breaches of MAS' AML/CFT requirements in relation to the case.

3 The penalties took into account various factors including the extent of the FI's exposure to the POIs, the number of breaches of MAS' requirements, and the degree of weakness in the FI's AML/CFT controls. The composition penalties are as follows:

4 The breaches were identified during MAS' supervisory examinations of the FIs from early 2023 to early 2025. Overall, MAS observed that most of the FIs had established AML/CFT policies and controls. The breaches arose out of poor or inconsistent implementation of these policies and controls. The FIs have embarked on remediation of the deficiencies and MAS will monitor their progress closely.

5 MAS found shortcomings in the areas of:

(a) Customer risk assessment. Five of the FIs (BJBS, BOIPL, Citi, CSSB, UOBKH) failed to implement adequate policies or processes for the rating of ML risks presented by some of their customers. This led to mis-rating of ML risks and affected their ability to apply appropriate controls to and address higher ML risks presented by several POIs.

(b) Establishing and corroborating source of wealth (SOW) of customers who posed a higher risk of ML. All nine FIs did not detect or adequately follow up on significant discrepancies or red flags noted in information and documents that should have cast doubt on some customers' purported SOW and which indicated increased risk of ML. In some cases, there was no corroboration of significant aspects of SOW.

(c) Transaction monitoring. Eight FIs (BJBS, Citi, CSSB, LGTS, UOB, UOBKH, TTCSPL, UBSS) failed to adequately review relevant transactions flagged as suspicious by their own systems. The relevant transactions were unusually large, inconsistent with the customers' profiles, or showed unusual patterns.

(d) Post-Suspicious Transaction Report (STR) follow-up. In relation to customers the FIs had filed STRs on, two FIs (UOB and UOBKH) failed to take adequate and timely risk mitigation measures, such as enhanced monitoring and reviewing their risk classification.

6 The composition penalty imposed on CSSB also takes into account its breaches of MAS' AML/CFT requirements in the period November 2017 to October 2023 in relation to accounts maintained by CSSB on behalf of certain US customers.

Regulatory actions against individuals

7 In addition, MAS has taken actions against individuals who were involved in managing the FIs' relationships with the POIs.

Prohibition orders

8 MAS has issued prohibition orders (POs) ranging from three to six years in duration to the following individuals

(a) Mr Tsao Chung-Yi, Chief Executive Officer and Executive Director (ED) of BOIPL. Mr Tsao was issued a six-year PO with effect from 1 August 2025;

(b) Ms Wong Xuan Ling, Chief Operating Officer (COO) of BOIPL. Ms Wong was issued a five-year PO with effect from 1 August 2025;

(c) Mr Hsia Lun Wei @Henry Hsia, ED and Relationship Manager (RM) of BOIPL. Mr Hsia was issued a three-year PO with effect from 30 June 2025; and

(d) Ms Deng Xixi, former RM of BOIPL. Ms Deng was issued a three-year PO with effect from 30 June 2025.

9 Mr Tsao and Ms Wong had failed as senior managers to ensure that the AML/CFT policies and controls in BOIPL kept pace with significant growth in its business in the three years since the company was set up. They failed to develop and implement adequate policies and controls in multiple areas, such as SOW corroboration, customer risk assessment, customer name screening and ongoing reviews of customer due diligence (CDD) information. They also failed to ensure that BOIPL's AML/CFT policies and controls were subjected to audit reviews. Mr Tsao, Ms Wong, Mr Hsia and Ms Deng also failed to raise red flags when they were aware of information that should raise suspicion and failed to perform enhanced CDD for multiple POIs.

10 For the duration of their POs, Mr Tsao, Ms Wong, Mr Hsia and Ms Deng are prohibited from carrying on any activity or business, or providing any service, the carrying on or provision of which is regulated or authorised by MAS, and from taking part, directly or indirectly, in the management of, or acting as a director, partner or manager of, any FI. They are also prohibited from becoming a substantial shareholder of any FI that is a corporation ; and if they are already a substantial shareholder of a FI that is a corporation, from acquiring any interest in any voting share in the FI other than a voting share in which they already have an interest. Further, Mr Tsao and Ms Wong are prohibited from performing the function of risk management and control.

Reprimands

11 MAS has issued reprimands to the following individuals for multiple lapses:

(a) For failure to ensure TTCSPL's compliance with MAS' requirements:

(i) Mr Sean Andrew Coughlan, Managing Director, ED and Resident Manager of TTCSPL;

(ii) Mr Tan Ho Kiat, COO, ED and Head of Compliance of TTCSPL; and

(iii) Ms Kek Yen Leng, ED, Head of Trust Administration, and Resident Manager of TTCSPL.

As senior managers of TTCSPL, Mr Coughlan and Mr Tan failed to ensure that TTCSPL's policies provided sufficient practical guidance on how to establish customers' SOW. Furthermore, Mr Coughlan, Mr Tan and Ms Kek failed as members of TTCSPL's New Business Committee to detect or adequately assess multiple deficiencies in customers' SOW corroboration when approving the onboarding of higher risk customers.

(b) For failures to conduct or ensure proper due diligence or post-STR follow-up in respect of several POIs:

(i) Mr Ang Sze Hee, Alvin, former Team Head of Group Retail Privilege Banking, UOB; and

(ii) Mr Tan Sheng Rong, Leonard, former Team Head of Group Retail Privilege Banking, UOB.