Trade finance and financial integrity

Bank exposure to commodity finance (end of 2021): S$109 billion, about 9 per cent of total credit exposure – Chapter H.II¹
Debts of Hin Leong (2020): about US$3.85 billion owed to 23 lenders – Chapters H.I and H.II²
Trade Finance Registry (February 2025): 40 participating banks, more than 18,000 queries – Chapter H.I³
Suspicious transaction reports received: 33,882 (2020), 49,846 (2022) and 85,988 (2024) – Chapter H.III⁴
Money laundering investigations (five years to 2024): 11,189, of which 7,594 referred for prosecution – Chapter H.III⁵
Assets confiscated (2020–2024): S$3.9 billion – Chapter H.III⁶
Money laundering case of 2023: more than S$3 billion of assets seized, more than S$940 million forfeited by the ten convicted persons and about S$1.85 billion surrendered by fifteen absconded suspects – Chapters E.VI and H.V⁷
MAS penalties after the 2023 case (4 July 2025): S$27.45 million on nine financial institutions – Chapters E.I and E.VI⁸
1MDB assets seized in Singapore: about S$240 million, of which S$15.3 million ordered to be returned to Malaysia in September 2018 – Chapters E.VI and H.V⁹
MAS enforcement (January 2025 to June 2026): 19 criminal convictions, S$29 million in financial penalties and compositions, 23 prohibition orders – Chapter E.I¹⁰
Seatrium deferred prosecution agreement (2025–2026): penalty of US$110 million, of which US$53 million could be offset against Brazilian payments – Chapter H.V¹¹

Notes

GTR, “Singapore authorities say commodity finance ‘stable’ amid growing market concerns”, 11 May 2022, as cited in Chapter H.II. ↩
Wikipedia, “Hin Leong”, as cited in Chapter H.II. Chapter H.I gives about US$3.5 billion owed to 23 banks. ↩
Association of Banks in Singapore and SGTraDex, joint media release, 12 February 2025, as cited in Chapter H.I. ↩
FATF and APG, Mutual Evaluation Report of Singapore, May 2026, Table 6.1, as cited in Chapter H.III. ↩
FATF and APG, Mutual Evaluation Report of Singapore, May 2026, Executive Summary, paras 30–31, as cited in Chapter H.III. ↩
FATF and APG, Mutual Evaluation Report of Singapore, May 2026, Executive Summary, as cited in Chapter H.III. ↩
Inter-Ministerial Committee on Anti-Money Laundering, Report, October 2024, “Key Facts”, and Wikipedia, “2023 Singapore money laundering case”, as cited in Chapter E.VI. ↩
MAS, “MAS Takes Regulatory Actions against 9 Financial Institutions for AML-Related Breaches”, media release, 4 July 2025, as cited in Chapter E.I. ↩
Wikipedia, “1Malaysia Development Berhad scandal”, section on Singapore, as cited in Chapter E.VI. ↩
MAS, Enforcement Report 2025/2026, 7 October 2026, headline figures on mas.gov.sg/regulation/enforcement, as cited in Chapter E.I. ↩
Clyde & Co, “DPA: corporate criminal liability in Singapore”, 21 August 2025, as cited in Chapter H.V. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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Dr Alexander Ressos, TEP

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I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

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