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Singapore publishes updated counter-terrorism financing strategy with lower casino due diligence threshold

Singapore has cut the cash deposit level at which casinos must run due diligence checks to S$4,000, part of an updated national strategy against terrorism financing published on July 1.

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Home › News › Singapore publishes updated counter-terrorism financing strategy with lower casino due diligence threshold

Singapore casinos will have to carry out due diligence checks when they receive a cash deposit of S$4,000 (US$2,950) or more into a customer's account, down from the current threshold of S$5,0001. The change was announced on Monday, July 1, as part of Singapore's updated National Strategy for Countering the Financing of Terrorism, jointly published by the Ministry of Home Affairs, the Ministry of Finance and the Monetary Authority of Singapore1. The updated strategy was published alongside the Terrorism Financing National Risk Assessment1.

The Gambling Regulatory Authority said the adjustment is meant to help casinos fight money laundering and terrorism financing and to align Singapore's requirements with standards set by the Financial Action Task Force, the global money laundering and terrorism financing watchdog1.

"The adjustment is made so that Singapore casinos can better combat money laundering and terrorism financing and align our requirements with FATF standards."
Gambling Regulatory Authority, July 11

This is the first revision to the threshold1. It will be implemented this year, but the authorities did not state when exactly the new requirements will take effect1. The strategy itself was launched in 20221.

The announcement follows enforcement action against a casino operator. In December 2023, Resorts World Sentosa was fined S$2.25 million for failing to carry out such checks, the biggest penalty the GRA has imposed on a casino operator1.

The risk assessment also set out how the authorities rank different sectors. Money remittances are classified as high risk, with cross-border online payments identified as a potential new channel for terrorism financing1. Banks are at medium-high risk, with new cross-border fast payment systems named as a potential new channel1. Digital payment token service providers were raised from medium-low to medium-high risk1. Non-profit organizations remain at medium-low risk, with foreign online crowdfunding flagged as an emerging concern1. Cross-border cash movements and precious stones, precious metals and precious products also stay at medium-low risk1.

SectorRisk level in 2024 assessment
Money remittancesHigh
BanksMedium-high
Digital payment token service providersMedium-high (raised from medium-low)
Non-profit organizationsMedium-low
Cross-border cash movementsMedium-low
Precious stones, precious metals and precious productsMedium-low

The authorities said self-radicalized individuals continue to pose the most salient terrorism financing threat to Singapore1. They named terrorist groups including ISIS, Al-Qaeda and Jemaah Islamiyah, and pointed to potential spillovers from the ongoing Israel-Hamas war and tensions in the Middle East1. The assessment took into account developments since its last edition in 2020, including the evolving global and regional terrorism landscape, growth of the digital economy and financial services in Asia, and emerging terrorism financing risk typologies1.

What it means for players

The threshold applies to cash deposits made into a customer's account at a casino, not to bets placed at tables or machines1. A deposit of S$4,000 or more will trigger due diligence checks once the change takes effect, where previously the trigger sat at S$5,0001. The checks are the casino's obligation, but they involve the customer, and the practical effect is that more deposits will now fall inside the screening net. The GRA has not said what the checks require of customers in each case, and that detail has not been reported1.

The change sits inside a wider national assessment that treats casinos as one channel among several, alongside remittances, banks and digital payment tokens1. For anyone gambling at casinos in Singapore, the deposit threshold is the part of the strategy that touches them directly. The rules on who may enter and the casino entry levy are unchanged by this announcement, and the casino exclusion orders regime is separate1. General background on what is legal across the region is set out in gambling laws in Asia, and the games available at the two integrated resorts are covered in casino games at Marina Bay Sands and Resorts World Sentosa.

What happens next

The GRA said the new threshold would be implemented this year but did not state when exactly the requirements would kick in1. No commencement date has been reported1.

Sources1 sources
  1. Singapore to tighten regulations to prevent misuse of casinos for terrorism financing - CNA, channelnewsasia.com