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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 14 August 2025

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Roles of Real Estate Salespersons and Estate Agents
Singapore’s Anti-Money Laundering, Countering Proflieration Financing, and Countering the Financing of Terrorism Regime
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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:

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 Terrorism Financing) Regulations 2021 (PDF, 686KB) to provide a step-by-step guide for RESs/ EAs to conduct CDD and UCPDD checks.

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 Terrorism Financing) Regulations 2021 (PDF, 686KB).  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 Terrorism Financing) Regulations 2021 (PDF, 686KB).

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 Terrorism Financing) Regulations 2021 (PDF, 686KB) for RESs/ EAs’ compliance.

Singapore’s Anti-Money Laundering, Countering Proflieration 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.

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