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Anti-Money Laundering / Countering the Financing of Terrorism Division
Notices from the Registrar

Environmental Crime Money Laundering National Risk Assessment

13 June 2024

Read the Environmental Crimes Money Laundering National Risk Assessment to understand Singapore's key threats and take steps to protect your business.

Dear Regulated Dealer,

The Environmental Crimes Money Laundering National Risk Assessment ("Env Crimes ML NRA") presents an overview of Singapore’s Env Crimes ML risk environment, identifies the key threats and vulnerabilities in environmental crimes ML that Singapore is exposed to, and outlines risk mitigation measures.

Singapore’s key exposure to environmental crimes ML stems from its position as a transit country:

  • As an international trading and transportation hub, Singapore is sited on the supply route where high volume of wildlife and environmental goods are moved using sea route, which make Singapore susceptible to trade flows arising from environmental crime.

  • As an international financial centre, there is potential for illicit funds from environmental crimes to flow through Singapore.

Singapore’s key environmental crimes ML threats come from:

  • Illegal wildlife trade

  • Illegal logging and the illegal timber trade

  • Trafficking of hazardous waste

Types of environmental crimes includes illegal mining, which refers to mining activity that is undertaken without state permission or with state permission obtained through corruption.

Corruption, bribery and tax evasion offences may also be linked to environmental crimes.

Why are environmental crimes a concern? 

Some of the key concerns highlighted in the report are:

  1. Environmental crimes and the laundering of their proceeds endanger the environment and have a far-reaching impact.

  2. Criminals could launder proceeds from environmental goods though layering, under the guise of loans or payments, and using cash deposits, electronic payments, and third-party wire transfers.

  3. Criminals may use shell companies to hide beneficial owners to launder proceeds from environmental crimes such as illegal mining.

  4. Proceeds from environmental crimes, or from corruption, bribery, or tax evasion linked to environmental crimes, may be used to purchase precious stones, precious metals, or precious products ("PSPM") to hide the illicit origin of these funds.

What can you do?

Regulated Dealers should take reference from the Env Crimes ML NRA in assessing your environmental crimes ML risks and enhance your controls as appropriate. You are encouraged to :

  1. Be alert to the potential vulnerabilities outlined in the Env Crimes ML NRA. PSPM tend to be good stores of value and accepted as an alternative to monies and could be used in the layering and integration of funds in ML transactions.

  2. Take the appropriate risk mitigation measures such as understanding, detecting and reporting suspicious transactions to guard against the Env Crimes ML risk that your business may be abused, where relevant.

Click here for the full Env Crimes ML NRA Report.

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