Offences/Breaches under the PSPM Act and PMLTF Regulations
Key offences and breaches and their corresponding maximum penalties that PSMDs must be aware of under the PSPM Act and PMLTF Regulations.
Last updated 1 May 2026
Table 1
Offence/Breach | Section | Nature of Offence/Breach | Maximum Penalty |
|---|---|---|---|
Unregistered dealing | Sec 6(2) | Acting as or holding out to be a regulated dealer without registration | Fine not exceeding $75,000 or to imprisonment for a term not exceeding 3 years or to both, and in the case of a continuing offence, to a further fine not exceeding $7,500 for every day or part of a day during which the offence continues after conviction |
Regulatory breach | Sec 10 | Regulatory breaches such as failure to comply with any condition of registration | Cancel registration, or suspend the registration for a period not exceeding 6 months, and/or financial penalty not exceeding $100,000 |
Customer due diligence (“CDD”), enhanced customer due diligence (“ECDD”) and ongoing monitoring | Sec 16(6) | Non-compliance with CDD requirements | Fine not exceeding $100,000 |
Cash transaction report (“CTR”) | Sec 17(4) | Non-compliance with CTR requirements | Fine not exceeding $20,000 or to imprisonment for a term not exceeding 2 years or to both |
Cash transaction report (''CTR'') | Sec 17(1A) | Incomplete or inaccurate submission of CTR | Fine not exceeding $20,000 or to imprisonment for a term not exceeding 2 years or to both |
Record keeping | Sec 18(5) | Contravention of record keeping requirements for regulated dealers | Fine not exceeding $100,000 |
Record keeping | Sec 18(1A) | Contravention of record keeping requirements for former regulated dealers | Fine not exceeding $100,000 |
Risk assessment and internal policies, procedures and controls (“IPPC”) | Sec 19(3) | Contravention of risk assessment and IPPC requirements | Fine not exceeding $100,000 |
Sanctions | Sec 20(2) | Contravention of measures related to targeted financial sanctions | Fine not exceeding $100,000 |
Suspicious transaction report (“STR”) | Sec 21(3) | Non-compliance with STR requirements | Fine not exceeding $20,000 |
Written directions | Sec 22(5) | Non-compliance with Registrar’s written directions | Fine not exceeding $20,000 |
Providing false information | Sec 27 | Provision of false information to Registrar or authorised officer | Fine not exceeding $50,000 or to imprisonment for a term not exceeding 2 years or to both |
Obstructing investigation | Sec 28 | Obstruction of investigation | Fine not exceeding $50,000 or to imprisonment for a term not exceeding 2 years or to both |
Table 2
Offence | Regulation | Nature of Offence | Maximum Penalty |
|---|---|---|---|
Notification of change in place of business | Reg 20(4) | Non-compliance with requirements to notify change in place of business | Fine not exceeding $20,000 |
Notification of change in particulars & circumstances | Reg 21(4) | Contravention of requirements to notify change in particulars and circumstances | Fine not exceeding $75,000 |
Regulated dealers are also required to comply with the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (“CDSA”), in particular Section 57 Tipping-off (Fine not exceeding $250,000 or to imprisonment not exceeding 3 years or to both).