Enforcement Actions Taken Against Two Real Estate Salespersons for Due Diligence Lapses Relating to the 2023 Major Money Laundering Case

July 2025 - 3 min read

In August 2023, the Police conducted its largest anti-money laundering (AML) operation to date, which led to the arrest of 10 foreign nationals and seizure of assets valued at approximately $3 billion, including real estate properties.

During this period, CEA commenced investigations into real estate salespersons (RESs) who had facilitated property transactions linked to the 2023 money laundering case.

This CEAnergy article highlights two cases of enforcement actions taken against RESs arising from these investigations. In both cases, CEA censured the errant RESs and imposed financial penalties on the RESs for breaches of anti-money laundering/countering financing of terrorism (AML/CFT) obligations under the Estate Agents (Prevention of Money Laundering and Financing of Terrorism) Regulations 2021 (PMLFT Regulations).

Case Study 1: Failure to Conduct AML Screening and Customer Due Diligence (CDD) Measures on Client

In January 2022, RES Tiew Chin Nee (Tiew) was engaged by a client X to source for an industrial property. Tiew facilitated the purchase of an industrial property for X in the same month and subsequently assisted X in renting out the property. In May 2022, Tiew successfully found a tenant for the property.

Prior to facilitating both the purchase and rental transactions, Tiew failed to screen X against the list of designated individuals and entities under the Terrorism (Suppression of Financing) Act 2002, and other relevant UN Sanctions lists. Tiew also failed to assess the risk of X engaging in money laundering or financing of terrorism and document the determination reached for the rental transaction, as required under the PMLFT Regulations.

For these lapses, Tiew was issued a Letter of Censure with the maximum financial penalty of $5,000 for breaching Section 44B(2)(a) of the Estate Agents Act 2010, in particular, for failing to perform the prescribed CDD measures under Regulations 4(1)(b) and 11(1) of the PMLFT Regulations. 

Case Study 2: Failure to Conduct CDD Measures with Due Diligence and Care

In September 2020, former RES Zhu Zhengxin (Zhu), who was a registered RES at the material time, represented a local company in the purchase of a commercial property. The beneficial owner of the company was Y, who was later convicted of money laundering and forgery charges. Y had approached Zhu to purchase the multi-million-dollar commercial property for investment and had incorporated the company for purposes of the purchase.

While Zhu had completed the Customer’s Particulars Form and CDD checklist for the local company, he failed to obtain a written acknowledgement (in the form of an authorised signatory’s signature and company stamp), to confirm the accuracy of the identifying information. Additionally, when submitting this documentation to his estate agent (EA), Zhu inaccurately indicated on the CDD checklist that he had obtained the above written acknowledgement even though he had not.

For his actions, Zhu was issued with a Letter of Censure with a financial penalty of $2,000 for breaching Paragraph 5(1) of the Code of Ethics and Professional Client Care for his failings. 

CEA takes a serious view of compliance with PMLFT Regulations

CEA is currently investigating other RESs who facilitated transactions of properties connected to the 2023 money laundering case and will not hesitate to take appropriate enforcement action against those found to have committed breaches or offences.

Under the PMLFT Regulations, EAs and RESs are required to:

• Carry out and maintain records of their Customer Due Diligence (CDD) measures, including all documents and information obtained during the process, for a minimum of five years.

• Report suspicious transactions or activities to the Suspicious Transaction Reporting Office (STRO) through the filing of Suspicious Transaction Reports.

• Implement internal policies, procedures and controls to prevent money laundering or financing of terrorism activities.

Those who fail to comply with the Estate Agents Act 2010 (EAA) and its subsidiary legislation may face disciplinary action by a Disciplinary Committee. This includes financial penalties and/ or revocation or suspension of the EA’s licence and RES’ registration. CEA may also issue Letters of Censure and/or impose financial penalties on the errant EA or RES under the EAA.

For more information, EAs and RESs may refer to CEA’s Preventing Money Laundering and Financing of Terrorism webpage, or email CEA at Inspection@cea.gov.sg. 

Information accurate as at 1 July 2025