Ministry of Law imposes Composition Sum on Singapore Precious Metals Exchange Pte Ltd and its CEO

The Ministry of Law imposes Composition Sum amounting to S$420,000 on Singapore Precious Metals Exchange Pte Ltd and its Chief Executive Officer

              The Ministry of Law (“MinLaw”) has imposed a composition sum amounting to S$210,000 on Singapore Precious Metals Exchange Pte. Ltd. (“SPME”) and another sum amounting to S$210,000 on its chief executive officer (“CEO”), Victor Foo Seang Kwang (“Mr Foo”). These were imposed for breaches of anti-money laundering and countering the financing of terrorism (“AML/CFT”) requirements under the Precious Stones and Precious Metals (Prevention of Money Laundering and Terrorism Financing) Act 2019 (“PSPM Act”) and Precious Stones and Precious Metals (Prevention of Money Laundering and Terrorism Financing) Regulations 2019 (“PMLTF Regulations”).

2          SPME is a precious stones and metals dealer registered under the PSPM Act. Its business activities include the sale and purchase of gold and silver bullion through its online store and operation of an online trading platform facilitating direct sales of gold and silver bullion between its customers.

3           MinLaw’s inspection of SPME uncovered serious breaches of the AML/CFT requirements under the PSPM Act and PMLTF Regulations between 2019 to 2022, including SPME’s failure to: 

(a)      take appropriate steps to properly identify, assess and understand SPME’s money laundering and terrorism financing (“ML/TF”) risk in relation to its customers;

(b)      identify and assess the ML/TF risk in relation to the business practice and take appropriate measures to manage and mitigate such risks before launching a new business practice;

(c)      perform enhanced customer due diligence on its customers; and

(d)      conduct ongoing monitoring of transactions to ensure customer profiles are consistent with their gold purchases and sales.

4            For the above offences, MinLaw has imposed a composition sum amounting to S$210,000 on SPME.

5            Additionally, a composition sum amounting to S$210,000 has also been imposed on Mr Foo, as CEO and director of SPME. Investigations found that the key breaches are attributable to Mr Foo, for failing to prevent or stop the commission of the offences by SPME. 

6            SPME and Mr Foo have paid the composition sum. They are in the process of taking remedial actions as directed by MinLaw, to address deficiencies related to the aforesaid offences.

7            Police investigations against SPME under Section 5 of the Payment Services Act is currently ongoing.

8            Regulated dealers dealing with customers or transactions that present higher ML/TF risks must take commensurate measures to mitigate such risks.  The senior management of regulated dealers must ensure that higher-risk customers and transactions are identified and subject to robust AML/CFT controls.  MinLaw will not hesitate to take firm regulatory action against regulated dealers that fail to meet the regulatory requirements for AML/CFT.                 

Additional Information:

Composition of ML/TF offences

Breaching of customer due diligence-related requirements and failure to implement adequate programmes and measures to prevent ML/TF are offences punishable under sections 16(6) and 19(3) of the PSPM Act respectively, where the prescribed fine is not exceeding S$100,000 per offence. An officer who, by omission, is party to the commission of the offences shall be liable on conviction to a fine not exceeding S$100,000 for each offence under section 32(2) of PSPM Act. The offence is compoundable under section 31(1) of PSPM Act.

Last updated on 20 Jun 2025