In October 2025, Singapore moved against Prince Holding Group, one of Cambodia’s largest conglomerates, whose founder, Chen Zhi, was charged in the United States for running a sprawling scam empire which used trafficked workers to carry out cryptocurrency investment fraud.

The Prince Group allegedly laundered billions of dollars by funnelling massive volumes of cryptocurrency across scores of virtual currency addresses, later reconsolidating them into fewer accounts to obscure the funds’ origins. A portion of these criminal proceeds was routed through Huione Group, a Cambodian financial services conglomerate, before ultimately being exchanged for traditional fiat money and stored in bank accounts. This is illicit capital flight today: velocity and fragmentation have replaced physical cash, rendering traditional tracing obsolete.

Yet digital laundering still requires physical off-ramps, and it is at this friction point that Singapore intervened. By March 2026, the state had seized over $500 million in Prince Group assets — an inventory echoing the landmark $3 billion money laundering case of 2023–2025.

For observers, the details of that infamous case were so delightfully gauche that they seemed almost scripted for Netflix. For me, having worked on the case within the regulatory system, the takeaway was even more thought-provoking. Money laundering is fought through relentless, coordinated enforcement — detecting criminal networks before they take root, sharing intelligence across borders, and bringing every available regulatory tool to bear.

Singapore is the conduit, not the theatre of the crime. That distinction matters: its anti-money laundering defences must be built not only for local wrongdoing, but for illicit funds moving quickly, quietly and across borders. Local enforcement cannot simply police the domestic front; it must operate as a global gatekeeper.

The recent cases show how that risk is changing. Criminal syndicates abroad are increasingly using digital channels, including the digital token payment sector, to move and disguise illicit funds at speed. The result is a laundering threat that is harder to detect, harder to trace and harder to contain.

The question for Singapore is not whether its defences are strong, but whether they are keeping pace.

The Report Card

That is why the latest assessment of Singapore’s anti-money laundering (AML) regime by the Financial Action Task Force (FATF) deserves attention. It provides an independent reality check of the efficacy of our defences and surfaces blind spots that we ought to address before criminals exploit them.

Released in May 2026, the global financial watchdog’s report recognises Singapore’s regime as strong and responsive. The Monetary Authority of Singapore (MAS) was lauded for its swift enforcement actions in the $3 billion money laundering case — in July 2025, MAS imposed S$27.5 million in penalties on nine financial institutions, among them Credit Suisse, UOB, and Citibank, and issued prohibition orders and reprimands against 18 individuals for AML breaches.

But FATF also points to areas where the system must improve: take more enforcement actions, especially in the digital payment token sector; impose more dissuasive sanctions; and share financial intelligence more widely to pursue complex money laundering networks.

To prevail in this fight, there are weapons Singapore may sharpen or forge.

The Weapon of Naming and Shaming

MAS has an effective enforcement regime. It can issue penalties against its regulated entities and issue prohibition orders against any individual in the financial sector, barring them, whether permanently or for a specified period, from performing roles or activities in the financial sector.

But there is a gap in the enforcement toolkit. The legislation does not give MAS the power to reprimand all individuals in the financial sector. A reprimand is issued in cases where the misconduct is not so serious to warrant a prohibition order. MAS may publish reprimands, which sting where it hurts most — reputation. Names are published. They tell the market that this individual fell short, and are an effective deterrent against AML lapses.

While the Securities and Futures Act gives MAS the power to reprimand certain individuals in the capital markets sector — those in customer-facing functions and senior management, for example — the Payment Services Act and the Financial Services and Markets Act (FSMA) do not have a reprimand provision. This means that individuals in the payment services sector, and compliance officers in the capital markets sector, are currently outside MAS’ sphere of reprimands.

The fix is simple: include a provision in the FSMA giving MAS the power to reprimand any individual in the financial sector. The FSMA is an omnibus Act designed to consolidate MAS’ regulatory powers into a single instrument, and to implement enhanced AML standards over digital payment token service providers. Including a reprimand provision in the FSMA would signal that there is no line of defence in our regulatory regime where lapses carry no personal consequence.

For the business community, compliance with AML rules is not a cost but an investment. Firms that invest properly in the fight against money laundering would welcome a regime that holds all individuals to account. A more precise enforcement toolkit that targets individuals who fall short ultimately makes Singapore a safer and more attractive place to park capital.

The Digital Battleground

The most active battleground for money launderers is now the digital payment tokens sector. With their speed, anonymity and cross-border reach, digital payment tokens are an obvious channel for moving illicit funds. The Prince Group case showed exactly how this works.

MAS has already demonstrated it is watching. In May 2026, for the first time, MAS revoked the license of a digital payment service provider due to significant weaknesses in its risk management practices. In June 2025, MAS imposed penalties totalling $960,000 on five major payment institutions for breaches of AML requirements, including failures to screen customers and inquire into beneficial ownership. MAS also tightened the licensing regime for digital token service providers under the FSMA, requiring entities serving only overseas customers to cease operations.

These are welcome steps. But stopping money launderers in the digital payment token space requires more. The quantum of the penalties for AML breaches is modest relative to the scale of risk — it must be increased to be dissuasive. Individuals in the payment services sector must be held to the same accountability standards as those in other financial sectors. And licensed digital payment token service providers must be brought into the intelligence-sharing fold.

A Shared Vigilance

One of the most promising weapons in Singapore’s AML arsenal is COSMIC (Collaborative Sharing of ML/TF Information and Cases) — a platform co-developed by MAS with six major banks (DBS, OCBC, UOB, Standard Chartered, Citibank and HSBC) in 2024 that enables the banks to voluntarily share information on suspicious customers with one another. The FSMA permits the sharing of such information, with controls to safeguard information security and confidentiality. MAS and the Suspicious Transaction Reporting Office (STRO), Singapore’s financial intelligence unit, also have access to information on COSMIC.

Two years on, COSMIC is working. In its first year, the platform contributed to an additional 461 suspicious transaction reports involving more than $1.6 billion, and the closure of 1,152 suspicious customer accounts. The 2026 FATF report found that COSMIC significantly improved the participant banks’ ability to detect bad actors. Think of it as a neighbourhood watch for the banking system — when one bank spots an unusual activity, it tells the others, who are then better enabled to disrupt account opening or illicit transactions. A criminal denied entry through one bank cannot simply try another.

But only six banks are on it. MAS took a phased approach, starting with these six major institutions, to allow the platform to achieve operational stability, ensure proper use and safekeeping of the information shared, and to build trust amongst the banks.

The time is ripe to expand — gradually and carefully — COSMIC’s participant base. FATF assessed that licensed digital payment token service providers and licensed trust companies, whose structures can obscure who truly controls the wealth, may be underreporting suspicious transactions. These are precisely the sectors that rogue actors are likely to exploit, and are currently outside the room where intelligence is being shared.

Bringing in a wider segment of the financial sector would not only improve detection, but also create a network effect. More participants mean more data points, more transaction patterns to cross‑reference, and a fuller picture of how funds move across institutions and asset classes. But expansion must be selective, bringing in participants that can demonstrate robust AML controls and strict security safeguards, so that one weak link does not undermine the whole network.

For licensed entities considering participation, the calculus is simple: the cost of joining a collaborative intelligence platform is marginal compared to the reputational and financial cost of being the institution through which a money laundering network operates.

Leading the Fight

Singapore’s strong FATF result is a vote of confidence from the international financial system. But confidence is not guaranteed — it must be maintained. As a major financial hub, Singapore will always attract rogue actors. Our job is to deter and fight them — to be the Rottweiler at the gate that makes them turn on their heels.