Singapore

BRIEFING PAPER

Prosecution &
International Co-operation of
Money Laundering & Terrorist
Financing in Singapore

Inside:

1. Introduction
2. Prosecution of Money
Laundering and Terrorist
Financing Offences
3. International co-operation

ICA International Diploma in

Financial Crime Prevention

Student ID: CON-000229948

1
Date: 16 April 2018
Singapore

Contents

1. Introduction…………………………………………………………………………………….....3

2. Prosecution of Money Laundering and Terrorist Financing offences………………………..4

2.1 Singapore Criminal Prosecutors…………………………………………………………..4

2.2 Special Agencies…………………………………………………………………………..5

2.2.1 Commercial Affairs Department (“CAD”)……………………….………….5

2.3 International Bodies……………………………………………………………………….7

2.3.1 Office of Foreign Assets Control (“OFAC”)………………….……………...7

2.3.2 United Nations (“UN”)……………………………………………………….7

2.3.3 International Criminal Police Organization (“INTERPOL”)……….………..8

3. International Co-operation……………………………………………………………….………9

Mutual Legal Assistance (“MLA”)………………………………………………………….……..9

i. Mutual Assistance in Criminal Matters Act (“MACMA”)…………………..……...…..9

ii. MLA Treaties………………………………………………………………..................10

b. Intelligence Sharing………………………………………………………………………12

c. Extradition……………………………………………………………………………….12

d. Beneficial Ownership (“BO”) Sharing…………………………………………………..13

4. Conclusion……………………………………………………………………………………….14

5. References……………………………………………………………………………………….15

2
Singapore

1. INTRODUCTION

The United Nations Office on Drugs and Crime estimated that 2-5% of the global Gross Domestic

Product was laundered annually. Despite tightened regulations and authorities’ efforts, money

laundering (“ML”) remained as one of the top five economic crimes in Singapore, according to PwC’s

2016 Global Economic Crime Survey.

Besides setting up Anti-Money Laundering Department by Monetary Authority of Singapore (“MAS”)

in 2016, the Anti-Money Laundering and Countering the Financing of Terrorism Industry Partnership1

(“ACIP”) was formed in 2017 to combat ML, terrorist financing (“TF”) and other financial crimes.

This paper examines national and international efforts of authorities and international organisations in

the banking industry to combat ML and TF.

1
ACIP is a Steering Group made up of eight banks and the Association Banks of Singapore to combat and
mitigate risks associated with ML/TF.

3
Singapore

2. PROSECUTION OF MONEY LAUNDERING AND TERRORIST FINANCING

OFFENCES

2.1. Criminal Prosecutors

In Singapore, the Attorney-General (“AG”) is the public and sole prosecutor which controls all

criminal prosecution and has powers to institute, conduct or discontinue any proceedings for any

offence.

AG consists of Criminal Justice Division (“CJD”) and Financial Technology Crime Division

(“FTCD”). FTCD is responsible for technology and financial offences while CJD is responsible for

the rest of the criminal prosecutions.

The AG discharges his responsibilities and duties through the Economic Crimes and Governance

Division, which is responsible for all prosecutions related financial crimes and corruption cases.

Case Study

Gift shop owner Jeanette Ang, sent five payments totalling more than USD$2 million in a month

to a stranger in United States (“U.S”). AG VK Rajah stated it was clear that Jeanette had

reasonable ground to believe that the monies were benefits of criminal conduct but yet she

proceeded to remit. This facilitated the retention and control of those benefits by the criminal. VK

Rajah emphasized, “A clear signal must be sent to those who might wish to conduct money

laundering activities here that if they are apprehended, they will be firmly dealt with.”

Singapore has zero tolerance in financial crime, which affects Singapore’s reputation as a financial

hub. Nobody can escape the law by pretending to be oblivious to potential ML acts.

4
Singapore

2.2. Special Agencies

2.2.1. Commercial Affairs Department (“CAD”)

The CAD is part of the Singapore Police Force (“SPF”) which investigates commercial and financial

crimes.

The Financial Investigation Division (“FIG”) is the specialist AML/CFT division responsible for

investigating and prosecuting ML/TF offences, assets confiscation of criminal proceeds and handling

foreign counterparts’ requests concerning transnational commercial crime. FIG also manages ML and

TF law enforcement policies.

5
Singapore

Case Study

In May 2016, six Bangladeshi nationals were charged under Terrorism (Suppression of

Financing) Act (“TSOFA”) for raising funds to facilitate terror acts in Bangladeshi. CAD’s

investigations revealed that they had formed a clandestine group named “Islamic State in

Bangladeshi” and solicited donations. The $1,360 raised was seized during the investigations and

they were sentenced to imprisonment.

Singapore takes a serious view of any support for terrorism-related activities whether or not the

funding will be used for terrorism in Singapore.

6
Singapore

2.3. International Bodies

2.3.1. Office of Foreign Assets Control (“OFAC”)

The U.S’ OFAC administers and enforces economic and trade sanctions and has extraterritorial effect.

OFAC publishes lists of targeted countries, individuals and entities that engaged in activities related to

proliferation of weapons of mass destruction and other threats related to national security, foreign

policy or economy of the U.S. The OFAC can block transactions and freeze assets.

Case Study

OFAC fined Singapore firm, CSE TransTel US$12 million for Iran sanctions violations. 104

payments were transferred to Iran through U.S for non-US goods and services through non-US

third parties in Iran. According to OFAC, “TransTel did not voluntarily self-disclose the apparent

violations”, which “constitute an egregious case” to OFAC.

2.3.2. United Nations (“UN”)

As a member of UN, Singapore gives effect to the sanctions under UN Security Council Resolutions.

The UN publishes sanctions measures against jurisdictions, individuals and entities. Under

international law, the funds and economic measures of these are to be freeze. MAS has issued the

relevant regulations accordingly and all Financial Institutions (“FIs”) are to comply with them. The

UN Regulations prohibit persons in Singapore to deal with UN-designated parties.

Case Study

Singapore-registered Chinpo Shipping Company (“Chinpo”) was fined for transferring funds to

facilitate cargo bound for North Korea and remitting money without valid license. The North

Korea-owned ship Chong Chon Geng, was carrying arms under sugar. All directors’ and

shareholders’ bank accounts were closed. District Judge stated that being a responsible member

of the international community, Singapore has a strong public interest in preventing breach of

UN sanctions.

7
Singapore

Sanctions attempt to prevent financial crimes without resorting to violence. By cutting financial

means, they will not have means to; for example, build warplanes or weapons. However, innocent

netizens have suffered due to sanctions. For instance, sanctions against Iran disallowed Iran from

maintaining their air fleet properly. In February 2018, Iran commercial plane Aseman Airlines

crashed, killing all 65 people on board. The plane was reportedly to have faced technical problems

midair a few weeks before the crash.

2.3.3. International Criminal Police Organization (“INTERPOL”)

INTERPOL is formed by police from 1922 countries to combat cross-border crimes. INTERPOL

facilitates investigations, operations and arrests. Each country member maintains a National Central

Bureau (“NCB”), the contact point for INTERPOL activities.

INTERPOL is involved in a wide range of crimes including ML and terrorism. They are combatted by

exchanging data and gathering experts globally. The INTERPOL General Assembly passed

resolutions to call on member countries to “concentrate their investigative resources in identifying,

tracing and seizing the assets of criminal enterprise”.

Singapore’s designated INTERPOL NCB, International Cooperation Department (“ICD”), part of

SPF, is responsible for all international engagement efforts with foreign counterparts.

Case Study

During the Euro 2016 football tournament, about 4,100 people were arrested in Asia, including

Singapore. In the INTERPOL-led operation, more than USD 649 million bets were collected by

illegal dens.

Per Head of INTERPOL’s Anti-Corruption and Financial Crimes Unit Jim Anderson, “The

successes of Operations would not have been achieved without global information sharing and the

significant efforts by the law enforcement authorities on the ground.”

2
There are 192 member countries as at 13 March 2018. Retrieved from:
https://www.interpol.int/Internet/Member-countries/World/(alpha)/1

8
Singapore

3. INTERNATIONAL CO-OPERATION

In Singapore’s latest Financial Action Task Force (“FATF”)’s Mutual Evaluation Report (“MER”),

Singapore was commended for its good international cooperation framework, with authorities making

high quality requests and providing high quality assistance.

3.1. International Instruments

Singapore has ratified the following Conventions:

(a) Vienna Convention;

(b) TF Convention;

(c) Palermo Convention;

(d) Merida Convention.

The ratification of Conventions indicated that Singapore consented to be bound to such treaties and

demonstrated Singapore’s commitment to cooperate with its foreign counterparts in combating ML

and TF.

3.2. Mutual Legal Assistance (“MLA”)

3.2.1. Mutual Assistance in Criminal Matters Act (“MACMA”)

The MACMA regulates Singapore’s MLA framework and governs MLA requests. MACMA permits

assistance on the basis of reciprocity in the absence of MLA treaty.

The AG Chambers (“AGC”) processes MLA. The types of assistance and requests forms are available

AGC’s website. Countries may use checklists to assess if MLA meets the requirements under

MACMA. This ensures that MLA requests are carried out efficiently.

Dual criminality is mandatory for coercive measures requested under MACMA, but not for non-

coercive measures and tax evasion offences in countries that have agreement with Singapore.

9
Singapore

Case Study

In 2011, owners of online gambling sites- PokerStars, Full Tilt Poker and Absolute Poker- were

charged with money laundering, fraud and illegal gambling offences. Billions of dollars flowed

out of US to offshore gambling sites as other types of financial transactions. Singapore’s

assistance, including production of bank records, assisted U.S in the resolution of the case.

3.2.2. MLA Treaties

Singapore has bilateral treaties with Hong Kong (“HK”) and India and bilateral treaty for drug

offences with the US.

For treaties with HK and India, the scopes of assistance include:

(a) Location and identification of persons;

(b) Service of documents;

(c) Obtaining statements and records;

(d) Arranging attendance of persons to give evidence; and

(e) Retraining and confiscating or forfeiting any property used in or derived from the commission

of offences.

Both treaties do not include extradition of any person and execution of final criminal judgements by

Requesting Party.

Singapore is a member to the ASEAN MLA treaty which has been ratified by 10 ASEAN countries to

improve effectiveness of their law enforcement authorities (“LEA”) in preventing, investigating and

prosecution of offences through cooperation and MLA in criminal matters.

International cooperation requires foreign counterparts’ cooperation for successful investigation and

prosecution. Any delays or no response from counterparts will hinder the investigations. All countries

10
Singapore

should timely respond to each other to combat financial crimes together before criminals plan their

next move.

Case Study

In 2010, CAD received information that illicit funds had been transferred out of Swiss account

to Singapore. The account holders have been convicted in foreign courts for embezzlement and

ML.

CAD investigated and discovered that they had USD 41 million in Singapore accounts. The

funds were seized but CAD required more information to be charged under Singapore

Confiscation of Benefits Act for ML offence.

MLA request was sent to Middle Eastern jurisdiction and requests for information through

Interpol channels. Despite several reminders and attempts of follow-up, the jurisdiction never

responded. This caused the funds being released due to absence of assistance from foreign

jurisdiction.

11
Singapore

3.3 Intelligence Sharing

The Financial Intelligence Unit (“FIU”) of Singapore is the Suspicious Transaction Reporting Office

(“STRO”). Besides analysing suspicious transactions to detect ML and TF, STRO provides financial

intelligence domestically and internationally.

A Memorandum of Understanding (“MOU”) or Letter of Understanding (“LOU”) is required when

exchanging information with foreign counterparts. STRO can exchange information in any nature

relevant to the investigation.

STRO is a member of Egmont Group which enables FIUs to share intelligence internationally. STRO

has signed MOUs/LOUs with more than 40 jurisdictions and is working with others to enter into one.

Case Study

Loh Yen-Lyng accepted a job offer to launder funds for an overseas fraudster. She received

commission by transferring and receiving “donations”. Loh’s bank filed STR when she

received funds from Turks and Caicos Islands and attempted to transfer them to a China bank

account. However, it was unsuccessful and she transferred them to HK instead.

STRO sent urgent request to Turks and Caicos authorities and confirmed that the transaction

was fraudulent. STRO contacted China’s FIU and knew about the attempt to deposit fraudulent

funds in China and obtained information from HK’s FIU regarding the monies received.

Loh was jailed for 9 months for ML offences.

3.4 Extradition

ML and TF are extraditable offences under Singapore’s Extradition Act (“EA”) and TSOFA

respectively.

Under the EA, Singapore has extradition arrangements with 40 declared Commonwealth countries of

the London Scheme and bilateral extradition treaties with U.S, HK and Germany. There were special

12
Singapore

extradition arrangements with Brunei and Malaysia. Singapore is party to International Convention

against the Taking of Hostages and the International Convention for the Suppression of Terrorist

Bombings.

Having a bilateral extradition treaty is useful in international cooperation as seen from the Standard

Chartered robbery case in 2016. The alleged robber fled to Thailand after the robbery. Singapore

wrote to Thai Government asking for assistance to repatriate the robber back but was rejected as

Singapore has no extradition treaty with Thailand. This showed that treaties play a substantial role in

international law and cooperation.

3.5 Beneficial Ownership (“BO”) Sharing

Singapore shares basic and BO information of legal persons and arrangements. LEAs share basic

information with foreign counterparts at no cost. Additionally, Singapore obtains additional BO

information for them using non-coercive investigative powers (e.g. voluntary disclosure of

documents).

Following the Panama Papers’ leak in 2016, Singapore has been tightening the regulations, including

identifying BO of trusts and corporations. One example is the amendment to Singapore Companies’

Act whereby locally incorporated and foreign companies registered in Singapore will have to maintain

registers of controllers at prescribed places.

13
Singapore

4. CONCLUSION

ML and TF will continue to be a major threat with criminals always trying hide their illicit gains from

crimes. By dealing with ML, we are also dealing with other crimes. Countries have to work together

to think ahead in order to thwart the next move of the criminals. As technology gets more advance, we

see AML compliance technologies increasingly necessary in the prevention of ML and TF.

14
Singapore

Reference List

Andrew Feldmen. (2011, Apr 16). Sites charged with gambling offenses. Retrieved from

http://www.espn.com/espn/poker/news/story?id=6362238.

ADB-OECD. (2007, Dec). Agreement between the Government of the Hong Kong Special

Administrative Region of the People’s Republic of China and the Government of the Republic of

Singapore concerning Mutual Legal Assistance in Criminal Matters. Retrieved from

http://www.oecd.org/site/adboecdanti-corruptioninitiative/39837878.pdf.

ADB-OECD (2017), Mutual Legal Assistance in Asia and the Pacific: Experiences in 31 Jurisdictions.

Retrieved from https://www.oecd.org/corruption/ADB-OECD-Mutual-Legal-Assistance-Corruption-

2017.pdf

Attorney-General Chambers- Overview of Functions. Retrieved from https://www.agc.gov.sg/our-

roles/public-prosecutor/public-prosecutor-overview-of-functions

Central Bureau of Investigation India. Agreement between the Government of the Republic of India

and the Government of the Republic of Singapore concerning Mutual Legal Assistance in Criminal

Matters. Retrieved from http://cbi.nic.in/interpol/mlat/Singapore.pdf.

Elena Chong. (2016, Jan 30). Singapore shipping company fined $180k for role in arms shipment to

North Korea. The Straits Times. Retrieved from: http://www.straitstimes.com/singapore/courts-

crime/singapore-shipping-company-fined-180k-for-role-in-arms-shipment-to-north

INTERPOL- Money Laundering. Retrieved from https://www.interpol.int/Crime-areas/Financial-

crime/Money-laundering

INTERPOL. (2016, Jul 18). More than 4,100 arrests in INTERPOL-led operation targeting Asian
illegal gambling networks [News]. Retrieved from: https://www.interpol.int/News-and-
media/News/2016/N2016-095

Kevin M. Stephenson, Larissa Gray, Ric Power, Jean-Pierre Brun, Garbriele Dunker, Melissa Panjer.
(2011). Barriers to Asset Recover.

15
Singapore

Lydia Lam. (2018, Jan 15). StandChart robbery suspect detained by British authorities, Singapore
working on extradition. The Straits Times. Retrieved from
http://www.straitstimes.com/singapore/stanchart-robbery-suspect-detained-by-british-authorities-
singapore-working-on-extradition

Michelle Quah. (2017, Mar 13). Changes to Companies Act take effect March 31. Retrieved from
http:// www.businesstimes.com.sg/companies-markets/changes-to-companies-act-take-effect-march-
31

Office of Foreign Assets Control (OFAC). Retrieved from

https://www.treasury.gov/about/organizational-structure/offices/Pages/Office-of-Foreign-Assets-
Control.aspx

PricewaterhouseCoopers. (2016). PwC’s 2016 Global Economic Crime Survey- Singapore:Economic

crime remains an obstinate threat in Singapore. Retrieved from
https://www.pwc.com/sg/en/consulting/assets/economic-crime-
survey/economic_crime_survey_2016_singapore.pdf

Rachel Boon. (2017, Apr 25). New Singapore offensive against money laundering, terrorist financing.
The Straits Times. Retrieved from: http://www.straitstimes.com/business/banking/offensive-against-
money-laundering.

Saeed Kamali Dehghan. (2018, Feb 18). Iran plane crash in south of country ‘kills all 65 onbaord’.
The Guardian. Retrieved from: https://www.theguardian.com/world/2018/feb/18/iran-plane-crashes-
aseman-airlines-yasuj

Singapore Police Force. (2015). Commercial Affairs Department Annual Report 2015.

Singapore Police Force. (2016). Commercial Affairs Department Annual Report 2016.

(2011). Ang Jeanette v Public Prosecutor. Retrieved from http://www.singaporelaw.sg/sglaw/laws-of-

singapore/case-law/free-law/high-court-judgments/14537-ang-jeanette-v-public-prosecutor-2011-
sghc-100

United Nations Office on Drugs and Crime. Money-Laundering and Globalization. Retrieved from
https://www.unodc.org/unodc/en/money-laundering/globalization.html

16
Singapore

Just A Little
“Coffee Money”
Would you accept that cup of coffee or be
that Barista who offers free coffee?
For stuffing $30 “coffee money” into the (CPIB) annual report.

police officer’s pocket twice, Sang Jia Weng

was jailed for 4 weeks. Sang bribed to avoid

summon for failing to secure his motorcycle

helmet strap. This demonstrated Singapore’s

zero tolerance in corruption, regardless the

size of bribe.

“Corruption reached record low” in

Singapore with 8% decrease in complaints,

according to 2016 Corrupt Practices

Investigation Bureau’s

17
Singapore
Low corruption does not mean no corruption.
Private sector cases remain high at 85% and
10% of them involved bribing public sectors
rejecting bribes from them. Although public
sector corruption is lower, the impact is huge.
Let us take a look at corruption in
Singapore’s public sector.
RISKS
Money Laundering Risk. In public firms,
third-party agents resort to bribery during
tendering process to win contracts.
Thereafter, there is a tendency for money
laundering as proceeds need to be concealed.
Case Study
Keppel Shipyard’s procurement officer was
charged for corruption and money
laundering in 2017 for accepting bribes in
exchange for business interests with Keppel
Shipyard. The proceeds were converted into
assets before transferring into various banks.
Reputational Risk arises when a company is
deemed to have anti-corruption measures in
place but got caught in a corruption scandal
(Andrea Bonime-Blanc, 2015). When a firm
hits corruption headlines, it will ruin its
reputation. A firm may be considered
responsible or conspiring for corrupt
payments even if they are oblivious to the
case.
Case Study
Singapore’s Keppel Offshore & Marine
(“KOM”) paid US$55 million bribes to
Petrobas officials and political party in
Brazil to win 13 contracts. KOM earned
USD $351.8 million through the bribery
scheme. KOM paid US$422 million in fines
as part of global resolution
Singapore ranked 6th in 2017 Transparency
International’s Corruption Perceptions Index
and has been well-known for one of the least
corrupted country. This case has tarnished
both KOM and Singapore’s reputation.
Senior Minister of State for Finance and Law,
Indranee Rajah, reiterated on Singapore’s
intolerance on corruption and “warned firms
not to “import” corrupt practices into
Singapore”. She added that government-
linked firms’ Board holds the responsibility
and would be replaced if they fall short of
standards.
18
Singapore

Third-Party Risk. According to Kroll’s VULNERABILITIES

Anti-Bribery and Corruption (“ABC”) Employees are vulnerable to corruption as

Benchmarking Report 2018, third-party risk they frequently deal with contractors. They

topped the list of perceived risks of firm’s may succumb to bribes to perform in their job

ABC program. In Ernst and Young’s 2013 or for private benefits. According to OECD

Knowing Your Third Party Asia-Pacific (2014), public sector officials and state-

Fraud Survey, Vendor/Supplier has the owned companies’ employees were most

biggest compliance risk. 90% of all bribery likely to be corruption’s target where they

criminal prosecutions under FCPA involved were promised, offered or given bribes in

third parties. Examples of bribing methods 80% of the cases.

include false invoices and inflated fees

In 2013, former Senior Investigation Officer
(Swift, 2014).
of Ministry of Manpower issued a Special
Case Study
Pass to a Chinese National to allow her to

Rolls-Royce fined £671m for corruption continue staying in Singapore in exchange for

cases, including 12 counts of conspiracy to sexual favours.

corrupt, false accounting and breaches to UK

Supported by Ernst and Young’s APAC
Bribery Act 2010, and failure to prevent
Fraud Survey 2017, 38%, 35% and 32% of
bribery by persons to obtain business. Most
respondents believe it is justifiable to offer
of the unlawful conduct involved third-party
entertainment, gifts/services and cash
intermediaries (“TPI”). Example includes
respectively to win and retain business.
employee working with two Russian TPIs to

ensure an official of the Russian state- Industry Types. Some industries are more

owned company, Gazprom, would receive a vulnerable to corruption, such as defence

proportion of the commission for his industry (OECD, 2017). Other industries

influence on a contract to supply Gazprom include offshore and marine, mining and

with gas compression equipment. natural resources and construction (Mak

Yuen Teen, 2016).

19
Singapore

This was mainly due to their huge contracts greater opportunities for corruption at

and secrecy by nature. The arms belong to bureaucratic level (Attila, 2008).

government and tendering process is

However, some studies showed otherwise.
compulsory. Third parties resort to bribery to
Dreher and Gassebner (2007) mentioned that
win contacts in the tendering process.
routine corruption may be efficiently

IMPACT ON ECONOMY enhancing. Supported by Leff (1964),

Reduced Foreign Direct Investment corruption might foster economic growth if

(“FDI”). FDI provides economic growth for under rigid regulation and inefficient

both host (lower cost) and foreign (funds bureaucracy. Blattman (2012) mentioned that

inflow) countries. Corruption turns away FDI corruption could improve efficiency and

as factoring bribes increases the costs. growth as bribes can act like a rate or price

However, according to World Bank (1997), discrimination and give faster or better

FDI may still flow to corrupted countries if service to firms with highest opportunity cost

the bribe is affordable and results are of waiting.

predictable. If corruption costs become

STRATEGIES
uncontrollable, host country may relocate.
Competitive wages and transparency in the

Corruption and Tax. Tanzi and Davoodi wage and promotion structure could reduce

(1997, 2000) concluded that corruption corruption. However, it must not be at the

reduces total tax revenues by reducing them expense of the firm and seen as if one has the

from taxable sources. Political corruption right to corrupt due to low wages.

caused politicians to abuse their powers by

Sweden’s corruption decreased in the 19th
introducing tax regulations favourable to
century when the public-sector administrators
industries with entrenched powers, which
were well paid and this reduced the
leads to inefficient tax structure (Farzana
temptations to bribes (Assar Lindbeck, 1998).
Nawaz, 2010). Inefficient tax structures erode
In Singapore, public servants are paid fairly
revenue base of the economy and creates
and realistic wages benchmarked to private

20
Singapore

sector earnings for highest standards of

Breaches include failing to conduct adequate
integrity and performance (Lee Hsien Loong,
risk assessments and third parties’ due
2016). Supported by Jakob Svensson (2005),
diligence.
Singapore’s civil servants’ pay relative the

private sector and are rotated routinely to Penalties and Rewards. Penalties are crucial

make it harder for corrupt official to develop in demonstrating zero tolerance to corruption.

strong ties to certain clients. It shows how one will be dealt with when

corruption occurs.
Due Diligence and On-going Monitoring
Case Study
(including screening) shall be performed on

new contractors and employees. Periodic on- A Singapore Police Officer was jailed for a

going monitoring shall be conducted on week for failing to arrest former colleague

existing ones. According to Kroll’s ABC who tried to bribe him despite turning it

report, about 50% of third party issues were down. He had bribed him and wanted him to

discovered through on-going monitoring. arrest a man who was alleged to be involved

Firms should have in place policies, in drug trafficking, bookmaking and illegal

procedures and approving authority regarding betting.

the process of due diligence. Although the officer rejected the bribe, he
Case Study
failed to report. The penalty serves as

Besso Limited was fined by UK Financial warning that it is punishable so long there is

Conduct Authority (“FCA”) for failing to an intent.

have tight controls against bribery which

Rewarding whistleblowers encourage others
“give rise to an unacceptable risk that
to do so as it increases public awareness.
payments made by Besso to third parties
Additionally, whistleblowing is more cost
could be used for corrupt practices,
effective as it is merely wealth transfers as
including paying bribes to persons connected
compared to the resources consumed by
with the insured or public officials”.
police officers and investigators. (Givati,

2016).
21
Singapore

Singapore set up a Corruption Reporting &

Heritage Centre which houses a corruption

gallery and allows public to make corruption

complaints. This measure encourages

complaints through whistleblowing.

According to the Association of Certified

Fraud Examiners (2014), tips are by far the

most common detection method. Although

Singapore does not reward whistleblowers,

some private organisations recognised the

importance of it (Lawrence and Jack, 2015).

CONCLUSION

Despite some studies arguing that corruption

is good, most of the research still proved that

corruption causes negative impacts. Although

third parties posed substantial risks, firms

cannot neglect other factors encouraging

corruption. Corruption cannot be fully

eliminated, but governments and firms should

try to prevent it. Everyone plays a part in

preventing bribery and corruption.

22
Singapore

Reference List

Alesina Alberto, Sule Ozler, Nouriel Roubini, and Phillip Swagel. 1996. Political instability and
economic growth. Journal of Economic Growth 1(2): 189-211. Retrieved from
https://dash.harvard.edu/handle/1/4553024.

Andrea Bonime-Blanc. (Feb 2015). Corruption: Reputation risk and opportunity. The GlobalEthicist.
Retrieved from https://gecrisk.com/wp-content/uploads/2015/12/ABonimeBlanc-Corruption-
Reputation-GlobalEthicist-February-2015.pdf.

Angela Teng. (Jan 9, 2018). Keppel scandal: Govt ‘extremely disappointed’, warns S’pore firms to
uphold integrity. Today. Retrieved from https://www.todayonline.com/singapore/keppel-bribery-
scandal-govt-extremely-disappointed-warns-spore-firms-uphold-integrity.

Angela Teng. (Dec 26, 2017). Keppel bribery scandal: Govt-linked firms should set the right example,
say experts. Today. Retrieved from https://www.todayonline.com/business/keppel-bribery-scandal-
govt-linked-firms-should-set-right-example-say-experts.

Assar Lindbeck. (1998). Swedish Lessons for Post-Socialist Countries. Retrieved from
https://pdfs.semanticscholar.org/09f3/3b124d1e0cd1599018a16dc1e1a83b546b2b.pdf

Association of Certified Fraud Examiners. (2014). Reports to the Nations on Occupations Fraud and
Abuse. Retrieved from https://www.acfe.com/rttn/docs/2014-report-to-nations.pdf.

Attila, G. (2008). Corruption, Taxation and Economic Growth: Theory and Evidence. CERDI-CNRS
Working Paper, 2008

Caroline Binham. (Mar 20, 2014). Besso fined £315,000 by FCA for insufficient bribery controls.
Financial Times. Retrieved from https://www.ft.com/content/f14e4968-af79-11e3-9cd1-
00144feab7de

Christopher Blattman. (Nov 5, 2012). Corruption and development: Not what you think? Retrieved
from https://chrisblattman.com/2012/11/05/corruption-and-development-not-what-you-think/

Corrupt Practice Investigation Bureau. (Jan 8, 2018). Contact Us. Retrieved from
https://www.cpib.gov.sg/contact-info

Dreher, Axel; Gassebner, Martin (2007). Greasing the wheels of entrepreneurship?: the impact of
regulations and corruption on firm entry, CESifo working paper, No. 2013. Retrieved from
https://www.econstor.eu/handle/10419/26058

Elena Chong. (May 4, 2017). Man jailed for offering $30 ‘coffee money’ to traffic police not to issue
him summons. The Straits Times. Retrieved from http://www.straitstimes.com/singapore/courts-
crime/man-jailed-for-offering-30-coffee-money-to-traffic-police-not-to-issue-him

Elena Chong. (Oct 3, 2013). MOM investigator jailed for receiving sexual bribes from Chinese
national. The Straits Times. Retrieved from http://www.straitstimes.com/singapore/mom-investigator-
jailed-for-receiving-sexual-bribes-from-chinese-national

23
Singapore

Elinor Lloyd .(May 2017). Rolls-Royce – a case study on the inappropriate use of third party
intermediaries. Retrieved from https://www.financierworldwide.com/rolls-royce-a-case-study-on-the-
inappropriate-use-of-third-party-intermediaries/#.WsQGI4huZdg.

Ernst and Young. (2017). Asia-Pacific Fraud Survey 2017. Retrieved from
https://fraudsurveys.ey.com/media/1334/ey_apac_fraud2017_preview-single.pdf.

Farzana Nawaz. (Jan 12, 2010). Exploring the relationship between Corruption and Tax Revenue.
Retrieved from
https://www.transparency.org/files/content/corruptionqas/228_Exlporing_the_relationships_between_
corruption_and_tax_revenue.pdf

Flat Icon. Icons retrieved from https://www.flaticon.com/

Highwaystarz-Photography. (Oct 21, 2014). Businessman Holding Tray of Takeaway Coffee [Digital
image]. Retrieved from https://www.istockphoto.com/sg/photo/businessman-holding-tray-of-
takeaway-coffee-gm519505871-49523408

Ivana Kottasova (2014). World’s most corrupt industries. Retrieved from

http://money.cnn.com/2014/12/02/news/bribery-foreign-corruption/index.html

Jakob Svensson (2005). Eight Questions about Corruption. Retrieved from

https://fortunedotcom.files.wordpress.com/2014/08/svensson_eight_questions_about_corruption_(jep
_vol_19,_no_3_2005).pdf

Jan Lee (Mar 27, 2018). Cop jailed for a week for failing to arrest friend who tried to bribe him. The
Straits Times. Retrieved from http://www.straitstimes.com/singapore/courts-crime/cop-jailed-a-week-
for-failing-to-arrest-friend-who-tried-to-bribe-him

Kroll. (2018). Anti-bribery and Corruption Benchmarking Report 2018.

Lawrance Lai and Jack Wong (Mar 30, 2015) Fight Graft by making whistleblowing easier. Today.
Retrieved from http://www.todayonline.com/singapore/fight-graft-making-whistleblowing-easier.

Lee Hsien Loong (2016). Fight Against Corruption: Singapore’s experience. The Straits Times.
Retrieved from http://www.straitstimes.com/opinion/fight-against-corruption-singapores-experience.

Leff, N.H., 1964, Economic Development through Bureaucratic Corruption, American Behavioral
Scientist 8: 8-14.

Singapore Police Force. (2016). Commercial Affairs Department Annual Report 2016. Retrieved from
https://www.cpib.gov.sg/sites/cpibv2/files/CPIB_Annual%20Report_2016.pdf

Tanzi, V., and H.R. Davoodi (1997). “Corruption, Public Investment, and Growth.” IMF Working
Paper No. 139, International Monetary Fund.

Tanzi, V., and H.R. Davoodi (2000). “Corruption, Growth, and Public Finances.” IMF Working Paper
No. 182, International Monetary Fund.

24
Singapore

World Bank (1997). Helping Countries Combat Corruption: The Role of the World Bank. Retrieved
from http://www1.worldbank.org/publicsector/anticorrupt/corruptn/cor02.htm

Yehonatan Givati (2016). A Theory of Whistleblower Rewards. Retrieved from: Retrieved from
https://www.journals.uchicago.edu/doi/pdfplus/10.1086/684617

(2016, Sep 1). Duo in Singapore jailed for international money laundering plot. Channel News Asia.
Retrieved from https://www.channelnewsasia.com/news/singapore/duo-in-singapore-jailed-for-
international-money-laundering-plot-7796910.

(2016, Dec 24). Keppel to take hit in earnings, but ‘will survive’. The Straits Times. Retrieved from
http://www.straitstimes.com/business/companies-markets/keppel-to-take-hit-in-earnings-but-will-
survive.

25