Preventing money laundering, proliferation financing, and terrorism financing
Real estate salespersons and estate agents play an important role to counter the threat of money laundering, proliferation financing, and terrorism financing.
Last updated 29 December 2025
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Industry Briefing: PMLPFTF Regulations Amendments (3 September 2025)
The Council for Estate Agencies (CEA) has conducted an industry briefing covering the key amendments to the Estate Agents Act 2010 and Estate Agents (Prevention of Money Laundering, Proliferation Financing and Terrorism Financing) Regulations 2021. You can refer to the briefing materials (PDF, 654KB).
Singapore is an attractive destination for investments and businesses due to its political and economic stability, rule of law, and transparency. However, this economic openness also poses a risk of money laundering, proliferation financing, and terrorism financing (ML/PF/TF).
Singapore is committed to its responsibilities on anti-money laundering, countering proliferation financing, and countering the financing of terrorism (AML/CPF/CFT) in accordance with the standards set out by the Financial Action Task Force (FATF), an intergovernmental task force that leads global action to tackle ML/PF/TF.
As a leading international financial centre, Singapore relies on various stakeholders such as financial institutions, real estate salespersons (RESs), lawyers, and corporate service providers, to combat ML/PF/TF.
Roles of real estate salespersons and estate agents
As a member of FATF, Singapore is committed to implementing its recommendations to combat ML/PF/TF.
For the real estate sector, property transactions involving large sums of money can be an attractive means for criminals and terrorist groups to perpetuate criminal deeds and launder tainted funds. As RESs and estate agents (EAs) are involved in the facilitation of property transactions, they serve as the first line of defence to counter the threat of ML/PF/TF.
More information on the 3 key roles of RESs/EAs:
1. Conducting Due Diligence Checks on Customers and Unrepresented Counterparties
As part of customer due diligence (CDD) measures, RESs/EAs must assess the risk of ML/PF/TF when you conduct property transactions for your clients. This involves verifying the identity of the client and beneficial owner, identifying risk factors such as nature and purpose of the transaction; and for higher risk transactions, to establish the source of wealth or source of funds of your client and the beneficial owner.
Where the counterparty is not represented by an EA/RES, EAs and RESs must conduct Unrepresented Counterparty Due Diligence (UCPDD) on the unrepresented counterparty (UCP) before their client enters into any agreement for the acquisition or disposition of property. This requirement applies to all rental, sale and purchase property transactions, with the exception of HDB residential rental transactions. Both CDD and UCPDD may be performed concurrently while preparing transaction-related paperwork.
EAs and RESs must screen clients, BOs, and UCPs against:
FATF's "Black and Grey" lists
Any lists provided by authorities
RESs and EAs are encouraged to subscribe to commercial AML/CPF/CFT screening solutions, which provide comprehensive databases, real-time screening capabilities and specifically designed for the real estate industry's compliance needs.
RESs who screen their clients/UCPs manually can take screenshots of the screening results with date/time-stamps as evidence of relevant screenings having been conducted. RESs must submit all relevant information and supporting documents obtained during the conduct of CDD/UCPDD measures to their EAs.
If RESs/ EAs suspect that you are dealing with designated individuals or entities in the UN Sanctions List of the First Schedule of TSOFA, you must file a Suspicious Transaction Report (STR), and cease any dealing for the client in the property transaction, unless the client or UCP has obtained an Exemption Order under the TSOFA.
To help RESs/ EAs comply with the required CDD and UCPDD measures, CEA has provided sample checklists in the Guide on Estate Agents (Prevention of Money Laundering, Proliferation Financing and Financing of Terrorism) Regulations 2021 (PDF, 803KB) to provide a step-by-step guide for RESs/ EAs to conduct CDD and UCPDD checks.
Here are some frequently asked questions by consumers relating to CDD measures.
Why am I being asked to provide information?
Under the Estate Agents (Prevention of Money Laundering, Proliferation Financing and Terrorism Financing) Regulations 2021 (PMLPFTF Regulations), all property agencies and property agents are legally required to conduct due diligence checks on both their clients and unrepresented counterparties in a property transaction, before any agreement to buy, sell, or lease a property is entered into. This means that:
(a) Where you are represented by a property agent in a transaction, your property agent is legally required to collect information from you.
(b) Where you do not have a property agent representing you, the property agent representing the other transacting party is legally required to collect information from you, as you are the unrepresented counterparty in the transaction.
What information do I need to provide?
The following is a non-exhaustive list of information that property agents are required to collect as part of due diligence checks:
For individuals
Full name (as per your identification document)
Date of birth
Nationality
Identification number (from your identification document, e.g. identity card, passport, or official document that has your photograph)
Occupation
For entities or legal arrangement (such as companies or express trusts)
Incorporation details
Information on the nature of business and the ownership and control structure
Identifying information of the individuals who ultimately have controlling ownership interest or effective control
The appointed property agents must also collect supporting documents, such as copies of original documents as evidence of the above information. In some situations, the agents may also need to verify your source of wealth or funds for the transaction.
Do these checks apply to all types of properties being transacted?
Yes, except for transactions involving the rental of HDB properties which are wholly for residential use.
What if I do not wish to provide such information?
Property agents are legally required to collect the information for purpose of due diligence checks. If you refuse to provide the required information, the property agent will be unable to fulfil their legal obligation to conduct due diligence and cannot proceed with the property transaction.
Is my information protected?
All property agents must comply with the Personal Data Protection Act in relation to information obtained during the conduct of due diligence checks.
You may ask your property agent or their agency about their data protection policies if you have any concerns.
2. Reporting Suspicious Transactions
The Suspicious Transaction Reporting Office (STRO) is responsible for receiving STRs. Filing of STRs provides the authorities with information so that investigation and appropriate enforcement actions can be taken.
A list of common suspicious indicators can be found in the Guide on Estate Agents (Prevention of Money Laundering, Proliferation Financing and Financing of Terrorism) Regulations 2021 (PDF, 803KB). RESs/ EAs who suspect that you are working with persons or properties connected to ML/PF/TF are required by law to report the suspicion to STRO through the STRO Online Notices And Reporting (SONAR). RES will need to file an STR through your EA. RES/ EAs are only required to file an STR and are not expected to conduct investigations.
The identity of the STR filer is confidential and protected by law, and any information disclosed by the RES/ EA in the STR will not be admitted as evidence in any civil or criminal proceedings.
Failure to file an STR if there are reasonable grounds to suspect that any property may be connected to a criminal activity is an offence under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992, and may be punishable by a fine, imprisonment, or both.
3. Establishing Risk Assessment, Internal Controls, and Compliance Procedures by Estate Agents
EAs must take appropriate steps to identify ML/PF/TF risks based on past transactions; assess and mitigate the ML/PF/TF risks; document the risk assessment and keep it up to date. In addition, EAs must develop and implement appropriate risk-based internal policies, procedures, and controls (IPPCs) to manage and mitigate higher risk property transactions, and have an ongoing programme to train its RESs on AML/CPF/CFT duties and the IPPCs.
EAs must also develop and implement independent internal checks and audits on their RESs and promptly address any non-compliance discovered (e.g., RESs did not comply with CDD and UCPDD measures and procedures where required).
All records relating to risk assessment, IPPCs, and compliance management arrangements must be kept in its original form or as a copy (may be in electronic form) for at least five years.
In order to better manage and effectively mitigate ML/PF/TF risks, EAs are required to appoint a Compliance Officer, who must be a designated officer of the EA (such as CEO, KEO, Director, Partner, or other officer authorised by the EA).
More details on the guidance for EAs can be found in the Guide on Estate Agents (Prevention of Money Laundering, Proliferation Financing and Financing of Terrorism) Regulations 2021 (PDF, 803KB).
CEA has prescribed the duties of RESs/ EAs on the prevention of ML/PF/TF under the Guide on Estate Agents (Prevention of Money Laundering, Proliferation Financing and Financing of Terrorism) Regulations 2021 (PDF, 803KB) for RESs/ EAs’ compliance.
Singapore’s Anti-Money Laundering, Countering Proliferation Financing, and Countering the Financing of Terrorism Regime
You can find out more information about Singapore’s AML/CPF/CFT regime.
Money Laundering National Risk Assessment
The ML National Risk Assessment (NRA) forms part of Singapore’s continuing efforts to maintain the effectiveness of its AML regime amidst the evolving risk landscape. It provides law enforcement agencies, regulators, supervisors, and industry players with a consolidated picture of the key national ML risks and vulnerabilities, allowing them to adopt a more targeted and focused approach towards the development and implementation of Singapore's national AML strategies and policies, and their own AML defences.
The findings from the updated ML NRA, together with other risk assessments conducted by the authorities, serve as a guide for all stakeholders, including the real estate agency industry, to continue to strengthen the implementation of risk-based measures in Singapore's fight against ML.
EAs and RESs should refer to the findings in this NRA to assist them in their risk assessments when running the EAs’ business and in the course of conducting estate agency work. The NRA findings will also assist the industry in implementing the appropriate risk mitigating controls and measures accordingly, and in turn contribute to the industry's role in Singapore's fight against ML.
You can find out more information and download a copy of the ML NRA from the MAS website.
Terrorism Financing National Risk Assessment
The TF NRA articulates the latest TF threats and vulnerable sectors in Singapore. It takes into account key developments since the last TF NRA in 2020, such as the evolving global and regional terrorism landscape, growth of the digital economy and financial services in Asia, and emerging TF risk typologies. Similar to 2020, the 2024 TF NRA has observed that the threat of raising and moving funds for terrorists and terrorism activities overseas remains pertinent in Singapore's context. Self-radicalised individuals continue to pose the most salient TF threat to Singapore.
EAs and RESs are reminded to screen your clients against the UN Sanctions Lists and TSOFA. In situations where EAs and RESs suspect that they are dealing with designated individuals or entities as defined in the UN Act or the TSOFA, they are required to file a STR, cease any dealings, and refrain from further dealings with the property or property transaction of the individual or entity, unless the individual or entity has obtained an Exemption Order under the TSOFA.
You may find out more information and download a copy of the TF NRA from the MAS website.
Proliferation Financing National Risk Assessment
The PF NRA identifies the key Proliferation Financing (PF) threats Singapore is exposed to, as well as higher-risk sectors. PF refers to the funding of weapons of mass destruction, including their delivery systems and related materials. Singapore is committed to complying with United Nations Security Council Resolutions (UNSCRs) to prevent PF.
As gatekeepers of the real estate sector, EAs and RESs must screen clients against UNSC-designated lists, report suspicious transactions to the STRO, apply enhanced due diligence for property transactions potentially linked to high-risk countries, and stay informed about PF risks and regulations.
For more detailed information and to download a copy of the PF NRA, please visit the MAS website.
Useful links & websites
Forms in the Guide on Estate Agents (PMLPFTF) Regulations 2021 (PDF, 531KB)
Ministerial Statements on Singapore's anti-money laundering regime (Delivered at Parliamentary session held on 3 October 2023)
National Anti-Money Laundering Strategy (Published on 31 October 2024)
Singapore's Law Enforcement Strategy to Combat Money Laundering (Published on 31 October 2024)
Industry briefing materials on the key amendments to the Estate Agents Act 2010 and Estate Agents (Prevention of Money Laundering, Proliferation Financing and Terrorism Financing) Regulations 2021 (PDF, 654KB) (Held on 3 September 2025)
Useful Websites