Enhanced requirements in real estate sector under Anti-Money Laundering and Other Matters (Estate Agents and Developers) Act 2025

29 July 2025

The Anti-Money Laundering and Other Matters (Estate Agents and Developers) Act 2025 (“Act”) came into operation on 1 July 2025. The Act amend three Acts - the Estate Agents Act 2010, the Housing Developers (Control and Licensing) Act 1965, and the Sale of Commercial Properties Act 1979. The Act is part of continuing efforts to bolster Singapore’s ability to detect and deter money laundering (“ML”), terrorism financing (“TF”), and proliferation financing (“PF”) within the real estate sector, thereby reinforcing Singapore’s commitment to stamp out the laundering of criminal proceeds and financing of illicit activities through Singapore.

The Act (i) strengthens current penalty frameworks; (ii) further aligns the regulatory regime with standards set by the Financial Action Task Force (“FATF”); and (iii) clarifies certain restrictions against convicted persons.

Strengthening penalty frameworks

  • Prescribe maximum financial penalties for estate agents and salespersons on a per contravention instead of per case basis: To ensure the penalty frameworks are sufficiently deterrent, the Estate Agents Act 2010 (“EAA”) has been amended to impose maximum financial penalties on a per contravention basis instead of on a per case basis previously. Errant estate agents and salespersons who are brought before a Disciplinary Committee for contravening any legislation or provision of a code of practice, ethics, and conduct relating to ML, TF, or PF will be subject to a maximum penalty of up to S$200,000 and S$100,000 per contravention respectively. Maximum penalties for other disciplinary breaches remain on a per case basis.
  • Increase maximum composition sums for housing developers and introduce composition framework for commercial/industrial developers: To strengthen deterrence, the Housing Developers (Control and Licensing) Act 1965 (“HD(CL)A”) has been amended to raise the maximum composition sum from S$5,000 to 50% of the maximum fine prescribed for the offence. Hence, the maximum composition sums for some offences have increased to S$50,000. The Sale of Commercial Properties Act 1979 (“SCPA”) has been amended to allow offences by commercial and industrial developers to be compounded. The maximum composition sum under the SCPA is up to 50% of the maximum fine prescribed for the offence.

Alignment with updated FATF standards

The amendments in the Act further align Singapore’s regulatory regime with international standards set by the FATF:

  • Estate agents and salespersons to conduct due diligence measures on unrepresented counterparties: Previously, estate agents and salespersons were only required to conduct due diligence measures on their own clients. To align with FATF standards, the EAA has been amended to require them to conduct due diligence measures on unrepresented counterparties of property transactions.
  • Estate agents, salespersons, and developers must consider PF risks: FATF has updated its standards to clearly set out the standards to identify, assess, and mitigate risks associated with PF. The Act has updated the regulatory regime for estate agents, salespersons, and developers to encompass PF. The amendments to the composition regime for developers allow PF offences to be compounded.
  • Clarify that measures for developers relating to targeted financial sanctions apply to TF and PF in addition to terrorism: The HD(CL)A and SCPA have been amended to require developers to perform prescribed measures related to targeted financial sanctions for TF and PF, in addition to terrorism. Previously, developers had to assess whether a purchaser was designated as a terrorist or terrorist entity under relevant lists or sanctioned by the United Nations. If so, developers must decline to enter into or terminate transactions with the potential purchaser, and report the matter to the Police. The amendments make clear that this requirement also applies to purchasers who are on the designated or sanction lists due to TF and PF.

Clarifying restrictions against convicted persons

The Act clarifies that persons who have been convicted of ML, TF, or PF offences, whether committed in Singapore or overseas, are not deemed fit and proper to hold an estate agent licence, or a salesperson registration under the EAA, given the seriousness of such offences.

The HD(CL)A and SCPA have been amended to clarify that ML, TF, or PF offences include offences under the law of any foreign country or territory. Persons convicted of such offences regardless of where they are committed will be subject to prohibitions against (i) becoming a housing developer; (ii) becoming a substantial shareholder; or (iii) holding a responsible position in a developer or in substantial shareholders of a developer.

URA circular and updated Guidelines for Developers on Prevention of Money Laundering, Proliferation Financing and Terrorism Financing have also been updated

On 1 July 2025, the Urban Development Authority (“URA”) issued a circular on “Enhanced Requirements for Developers against Money Laundering, Proliferation Financing and Terrorism Financing” (“Circular”). The Guidelines for Developers on Prevention of Money Laundering, Proliferation Financing and Terrorism Financing have also been updated.

Reference materials

The following materials are available on the Government Gazette egazette.gov.sg and the URA website www.ura.gov.sg: