Singapore to Lower Due Diligence Thresholds for Casino Cash Deposits Amid Tighter Counter-Terrorism Controls

Singapore's authorities have announced plans to lower the threshold for performing due diligence checks on cash deposits in casinos, amidst tighter controls on counter-terrorism financing (CFT). The new measure involves reducing the threshold to SG$4,000 ($2,950) from the previous SG$5,000 ($3,700) to align with Financial Action Task Force (FATF) standards. Although the measure is set to take effect this year, no specific timeline has been provided.

Currently, only two casinos are permitted to operate in Singapore: Marina Bay Sands and Resorts World Sentosa.

A joint statement released on Monday by Singapore’s Ministry of Home Affairs, Ministry of Finance, and Monetary Authority indicates that "money remittances remain at High risk," while "cross-border cash movements remain at Medium-Low risk" and "digital payment token service providers have been elevated from Medium-Low to Medium-High risk."

An update from the 2020 guidelines, as outlined in the 'National Strategy for Countering the Financing of Terrorism (NSCFT),' specifies that customer due diligence (CDD) will be applied to "all financial transactions" in the casino sector. "This adjustment aims to strengthen deterrence and prevent misuse of Singapore’s casinos for TF (terrorism financing) purposes," the statement read.

Regarding the FATF, the international body notes that Singapore is compliant with 20 of its 40 recommendations, largely compliant with 17, and partially compliant with three. A possible onsite assessment of Singapore’s compliance with FATF’s recommendations is scheduled for August 2025, while the last evaluation was conducted in June 2016.

Unlike the Philippines, Singapore is not on the FATF ‘grey list’ for increased monitoring by the international oversight body. Myanmar is currently on the FATF’s ‘black list,’ designated as a ‘high-risk jurisdiction subject to a call for action,’ with the list updated in June of this year.

In alignment with these initiatives, which span multiple government agencies and departments, the group plans to "conduct enhanced surveillance and supervisory activities focused on higher TF risk areas and entities," as well as "engaging with the industry through outreach, guidance, and industry cooperation initiatives."

The focus includes DFNBPs (designated non-financial businesses and professions), under which casino operators are classified. According to the national strategy (NSCFT), aligning with FATF standards means not only "identifying and verifying customers," "conducting ongoing monitoring and regular customer due diligence" (with enhanced measures for high-risk individuals), "conducting screening to ensure compliance with CFT requirements," and "promptly filing suspicious transaction reports."

For casino operators in Singapore, STR reports are required before the end of each applicable reporting period involving "every cash transaction with a patron involving either cash in or cash out of SG$10,000 ($7,400) or more in a single transaction." This also applies to "multiple cash transactions which the casino operator knows are entered into by or on behalf of a patron," aggregating to SG$10,000 or more "in any gaming day." Failure to comply can result in a fine of up to SG$20,000 ($14,800).

In its Money Laundering Risk Assessment Report for 2024, the Monetary Authority of Singapore (MAS) ranked casinos as having a ‘Medium High ML risk,’ despite posing a less serious threat than Corporate Service Providers (CSPs) and the real estate sector. The report noted, "we have not encountered any instance where the casinos were found to be directly complicit in ML activities in Singapore and have only observed a low number of cases where criminal proceeds were converted to casino chips for self-laundering purposes."

The MAS further indicated that its investigative unit "observed that the majority of STRs filed by casinos do not relate to potential ML offenses and instead involve a suspicion of offenses under the Casino Control Act or are filed pursuant to adverse news on casino patrons."

The upcoming change to the threshold for cash deposits was highlighted in the assessment, published on June 20th of this year. It indicated that the Gaming Regulatory Authority (GRA) "will be imposing legislative amendments to lower the prescribed CDD threshold for casino transactions, and to align them with the FATF Standards." To ensure compliance with both AML and CFT measures, the GRA "will continue to perform risk-focused monitoring and inspections of the casino operators commensurate with the moderately higher risks presented by the sector."

By fLEXI tEAM