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Singapore MAS Enforcement Report 2022: July 2020 to December 2021

29th April 2022 | Singapore

The Monetary Authority of Singapore (MAS) has released the Singapore MAS Enforcement Report 2022: July 2020 to December 2021, with key highlights on enforcement outcome including 3 individuals sentenced to imprisonment, $2.59 million in financial penalties & compositions, 20 Prohibition Orders (Unfit representatives banned from re-entering the financial industry), lifetime ban and 100 months imprisonment.  MAS Executive Director (Enforcement) Peggy Pao: “MAS has continued to take robust enforcement actions against errant firms and individuals so as to safeguard the integrity of our financial sector. We have also proposed legislative changes to enhance our effectiveness in addressing financial misconduct. We will continue to improve our processes to uphold Singapore’s reputation as a trusted financial centre that takes a tough approach to financial crime and misconduct.” See below for key highlights | View: MAS Enforcement Report 2022

“ $2.59 million in penalties, 20 Prohibition Orders, lifetime ban and 100 months imprisonment “


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Singapore MAS Enforcement Report 2022: July 2020 to December 2021

Singapore Financial District


Singapore MAS Enforcement Report 2022: July 2020 to December 2021
Key Areas of Focus
  • Market Abuse
  • Financial Services Misconduct
  • Money Laundering-Related Control Breaches
Enforcement Outcome
  • 7 Criminal Convictions 
  • 3 individuals sentenced to imprisonment
  • 4 individuals fined 
  • $2.59 million in Financial Penalties and Compositions (1 individual and 16 FIs)
  • $150,000 in Civil Penalties in relation to market rigging by 2 former trading representatives
  • 20 Prohibition Orders, Unfit representatives banned from re-entering the financial industry
  • 1 Licence Revocation Issued to  fund management company
  • 23 Reprimands Issued to 5 individuals and 18 FIs
  • 157 Warnings Issued to 27 individuals and 130 FIs/companies
  • 88 Letters of Advice Issued to 61 individuals and 27 FIs/companies
  • 362 Supervisory Reminders Issued to 8 individuals and 354 FIs
Average Time for MAS Reviews & Investigation
  • 9 months Criminal Prosecutions
  • 19 months Civil Penalties
  • 9 months Regulatory Actions
  • 4 months Referrals to External Agencies
  • 7 months Average across all Concluded Cases
Major Ongoing Cases 
  • Noble Group
  • Hyflux
  • Eagle Hospitality Trust
  • Hui Xun Asset Management (Formerly Envysion Wealth Management)
Featured Case 1 – Significant Prohibition Orders Issued
  • 17-year Prohibition Order, Sentenced to 100 months’ imprisonment.
  • Former Treasury Adviser, Lu Chor Sheng (Lu) used the OCBC accounts of a friend to place unauthorised forward foreign exchange (FX) trades at off-market rates in OCBC’s system, so that he could buy lower and sell higher than the prevailing market rates. 
  • To realise profits, Lu placed additional unauthorised trades in his customers’ accounts as counterparties to the trades placed in his friend’s accounts.
  •  Lu also instigated his friend to impersonate his customers to place unauthorised forward FX orders. OCBC suffered a total loss of $3.09 million as a result of these unauthorised trades.
Featured Case 2 – Significant Prohibition Orders Issued
  • 10-year Prohibition Order, Sentenced to 26 months’ imprisonment in June 2020.
  • Mr Ahmadnawar Bin Abd Karim (Ahmadnawar) solicited investments from at least 32 individuals to manage their monies and trade in foreign exchange on their behalf, without the requisite fund management licence.
  • Ahmadnawar cheated two investors of approximately $132,000 by inducing them to transfer monies to him for investments but used some of the monies to repay other investors and for his own personal expenses instead.
Featured Case 3 – 1MDB Actions against FIs and Individuals
  • Kevin Michael Swampillai – Lifetime POs
  • Received about US$5 million of secret profits while assisting 1MDB with its investments as Head of Wealth Management Services at BSI Bank.
  • Made misrepresentations to 1MDB’s auditors in an attempt to improperly influence the audit outcome.
Featured Case 4 – 1MDB Actions against FIs and Individuals
  • Goldman Sachs Group Inc (GSG) entered into a Deferred Prosecution Agreement (DPA) with the Department of Justice of the United States
  • AGC, CAD and MAS worked closely with the US authorities in relation to Goldman Sachs (Singapore) Pte. (GSSP)’s role in the 1MDB bond offerings. 
  • As part of the global resolution, GSSP paid US$122 million to the Singapore Government, pursuant to a conditional warning issued to it by CAD for offences under the Prevention of Corruption Act.
Featured Case 5 – Significant Composition Penalties Imposed for AML/CFT offences
  • Penalties of $1 million and $1.1 million for serious breaches of AML/CFT requirements on Bank J. Safra Sarasin Ltd, Singapore Branch (BJS) and Vistra Trust (Singapore) Pte Ltd (VTSPL) respectively.
Featured Case 6 – Breach of Requirements Regarding Remuneration of Supervisors
  • Reprimands against 4 FIs and 2 Individuals
  • MAS reprimanded AIA Financial Advisers Private Limited, Prudential Assurance Company Singapore (Pte) Limited, Aviva Ltd, and Aviva Financial Advisers Pte Ltd (Aviva FA) for breaching regulatory requirements related to risk management arrangements and the remuneration of supervisors.
  • Aviva FA’s ex-CEO and Director, Mr Lionel Chee, was reprimanded for failing to discharge the duties of his office. As CEO, he did not properly address the issue of poor conduct of Aviva FA’s representatives, despite repeated supervisory engagements with MAS. He also failed to ensure that Aviva FA put in place arrangements to ensure that Mr Tan Shou Yi, Peter^ (Mr Tan), who was hired as a consultant, did not act as a supervisor in respect of Aviva FA’s representatives.
Featured Case 7 – Coordinated Market Manipulation in Koyo International Shares
  • Following the share price crash, Koyo’s market capitalisation fell $58 million to $14 million. 
  • This resulted in substantial losses by brokerage firms and Koyo shareholders.
  • 3 months’ to 20 months and 18 weeks’ imprisonment
  • 4 to 15-year prohibition orders
Featured Case 8 – Market Rigging in Gaylin Holdings Shares
  • Wong Leon Keat (Wong) was a director of WLA Regnum Pte Ltd, which provided corporate advisory services to Gaylin Holdings Ltd (GHL) before it was listed on the Singapore Exchange in October 2012.
  • Wong purchased GHL shares on 17 occasions and caused GHL shares to close 6.5% to 38.6% higher.
  • 8 weeks’ imprisonment for false trading
  • $30,000 fine for unauthorised trading


2020/2021 Enforcement Priorities

Corporate Disclosures 

  • MAS commenced investigations into and arrested current and former directors responsible for managing Eagle Hospitality Trust.
  • MAS’ investigations into Noble Group Limited are also at an advanced stage. 

Financial Advisory Conduct 

  • MAS continued to engage the industry on initiatives to detect potential mis-selling and other forms of misconduct using data analytics. As part of the outreach, MAS shared with major insurers at our regular MAS-LIA dialogue on how FIs can analyse transactional data to identify potential suspicious transactions or red flags. 

Anti-Money Laundering and Countering the Financing of Terrorism Compliance 

  • MAS continued to conduct inspections of FIs and has taken robust enforcement actions against FIs where severe deficiencies in AML/CFT controls were uncovered. MAS imposed a total of $2.4 million composition penalties against four FIs. 

Enhancing the Enforcement Toolkit 

  • MAS introduced the Financial Services and Markets Bill 2022 in Parliament, which provides for a harmonised and expanded power to issue prohibition orders (POs). The new power broadens the categories of persons who may be subject to POs, streamlines the grounds for issuing POs from a list of specific criteria into a single fit and proper test, and widens the potential scope of POs to cover functions that are critical to the integrity and functioning of FIs. Separately, MAS also consulted on proposals to strengthen its investigative powers under MAS-administered Acts. 

Senior Management Accountability 

  • MAS held senior management accountable for breaches by their FIs through enforcement action. The ex-CEO and Director of Aviva FA was reprimanded for failing to ensure that the company put in place compliance arrangements to monitor the conduct of its representatives and an external consultant’s activities within the company. 


2022/2023 Enforcement Priorities

  • Corporate Disclosures
  • Business Conduct
  • AML/CFT Compliance
  • Investor Compensation
  • Senior Management Accountability

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