URA issues circular on risk-proportionate approach in prevention of money laundering, proliferation financing, and terrorism financing for developers

30 July 2026

On 7 July 2026, the Urban Redevelopment Authority (“URA”) issued a circular on “Risk-proportionate approach in prevention of money laundering (ML), proliferation financing (PF) and terrorism financing (TF) for developers’ property sales”.

Property developers in Singapore are required to have adequate controls to detect and deter money laundering, proliferation financing, and terrorism financing (“ML/PF/TF”) in accordance with the requirements and guidelines set out by the Controller of Housing (“COH”). For more on these requirements, please refer to our article “Enhanced requirements in real estate sector under Anti-Money Laundering and Other Matters (Estate Agents and Developers) Act 2025”.

URA advises property developers to implement ML/PF/TF controls such as customer due diligence (“CDD”) and screening processes in a risk proportionate manner that is commensurate with the nature and complexity of the property transactions, taking into consideration the risk profile of the purchasers.

CDD and ECDD checks

Developers are only required to conduct CDD checks for the vast majority of purchasers who are not assessed to be of higher ML/PF/TF risks. These include standard measures to identify and verify the identity of the purchasers and beneficial owners, and to screen these persons. Source of wealth (“SOW”) and source of funds (“SOF”) checks are not required for such purchasers.

For purchasers assessed to be of higher ML/PF/TF risks, developers are required to perform enhanced customer due diligence (“ECDD”) checks entailing SOW and SOF checks. These purchasers include foreign politically exposed persons and individuals from or in a country or jurisdiction in respect of which the Financial Action Taskforce has called for countermeasures or identified to have inadequate measures to counter ML/CP/TF or notified by COH.

URA reminds developers that, should there be any suspicion of illicit activities or funds, a Suspicious Transaction Report should be filed with the Suspicious Transaction Reporting Office as soon as is reasonably practicable.

Developers should ensure that their purchasers are not on the relevant sanctions lists, including the United Nations Security Council sanctions list, and they should cease dealings with purchasers if they are sanctioned. Developers may subscribe to the Monetary Authority of Singapore’s website and the United Nations Security Council Consolidated Lists to stay updated on the latest list of designated individuals and entities.

Third parties may be engaged to conduct the required CDD/ECDD checks at the point of sale, provided the engagement and reliance meet the requirements set out in the relevant regulations.

Targeted and risk-proportionate SOW establishment

In conducting ECDD checks to establish the SOW and SOF of the purchaser, developers should take appropriate and reasonable means to independently corroborate information obtained from the purchasers against documentary evidence or public information sources.

SOW and SOF checks should be risk proportionate and reasonable, taking into account the unique circumstances and profile of each purchaser. Instead of adopting a one-size-fits-all approach, developers should consider the following risk principles of relevance, materiality, and prudence:

  • Focus on obtaining relevant and pertinent information (e.g. income tax statement, audited accounts) without the need for unnecessary information such as long-dated financial or employment records.
  • Avoid excessive measures and requesting for irrelevant information to establish purchasers’ SOW/SOF that are disproportionate to COH’s requirements. For example, if the SOW originates from low-risk countries or is backed by reliable sources of information such as audited accounts of companies, bank statements, or salary slips from established companies, it would be deemed less risky as compared to wealth originating from higher risk countries and shell companies, or if it comprises gifts from unrelated parties.
  • Where information obtained is already from reliable and public information sources, it is not necessary to carry out triangulation checks against different information sources.
  • It is not necessary to attempt to corroborate every piece of SOW information gathered. Instead, developers should focus on corroborating the more material and higher risk SOW and assess whether the residual risk of the uncorroborated wealth is acceptable, and whether additional risk mitigating measures are needed in absence of the corroboration.
  • For transactions involving a single property purchase at price points reflecting market norms, less checks would be expected.

Revised Guidelines for Developers on Prevention of Money Laundering, Proliferation Financing and Terrorism Financing

URA has issued the revised Guidelines for Developers on Prevention of Money Laundering, Proliferation Financing and Terrorism Financing (Version 1.4) to provide more detailed guidance on the CDD process and simplify the risk assessment template that developers may use to perform a risk analysis of their projects.

Reference materials

The following materials are available on the URA website www.ura.gov.sg: