Customer due diligence cash transaction threshold of $4,000 takes effect

Singapore's customer due diligence threshold for a single cash transaction took effect on 14 November 2024, when Act 24 of 2024 was brought into force¹. The change sits in section 139 of the Casino Control Act 2006, the provision headed "Customer due diligence measures to combat money laundering, terrorism financing and financing of proliferation of weapons of mass destruction"¹.

The commencement is recorded in the Act's amendment history as "[Act 24 of 2024 wef 14/11/2024]"¹. The same consolidated text carries other commencement dates for separate amendments, including Act 29 of 2024 with effect from 30/10/2024, Act 31 of 2023 with effect from 31/12/2024, Act 1 of 2022 with effect from 01/03/2022 and Act 14 of 2022 with effect from 01/08/2022¹. A later consolidation of the same Act records Act 31 of 2023 with effect from 01/12/2025².

The Act sets out the regulator's role and the limits on the market it oversees. "Authority" means the Gambling Regulatory Authority of Singapore, which is the Casino Regulatory Authority of Singapore continued and renamed under section 3 of the Gambling Regulatory Authority of Singapore Act 2022¹. The Authority must, during the period ending on and including 31 December 2030, ensure that there are not more than 2 casino licenses in force at any particular time, and a casino license applies to one casino only¹.

The Act also carries penalties for casino offenses. Operating a casino without a valid license carries, for a first offense, a fine not exceeding $500,000 or imprisonment for a term not exceeding 7 years or both, and a further fine not exceeding $50,000 for every day or part of a day the offense continues after conviction; for a second or subsequent offense, a fine not exceeding $700,000 or imprisonment for a term not exceeding 10¹. In one case the court "is to order the payment by that person of a sum which is equal to that person's gross gaming revenue for the period that the offense was committed, and any such payment ordered is recoverable as a fine"¹. For an individual, one offense carries a fine not exceeding $125,000 or imprisonment for a term not exceeding 3 years or both¹.

The published text does not set out the detailed customer due diligence steps that apply at the $4,000 threshold, and no further guidance on how casinos must apply the threshold has been reported in these documents.

What it means for players

The threshold applies to casino operators, not to players directly, so it changes what a casino must do when a customer conducts a single cash transaction at or above $4,000. The requirement covers transactions in Singapore's two licensed casinos, the only casino licenses permitted under the Act¹. It applies to locals, expats and visitors alike, since it is tied to the transaction rather than to residency. The Act's customer due diligence provision is aimed at money laundering, terrorism financing and financing of proliferation of weapons of mass destruction¹. For background on the jurisdiction, see Gambling Laws in Asia: What Is Legal in 12 Jurisdictions and Can I Gamble in Singapore?.

What happens next

No further dated steps connected to the $4,000 threshold have been reported. The Act's amendment history lists other commencement dates that have already passed, including Act 29 of 2024 with effect from 30/10/2024 and Act 31 of 2023 with effect from 31/12/2024, with a later consolidation recording Act 31 of 2023 with effect from 01/12/2025¹.