URA releases revised Guidelines for Developers on Anti-Money Laundering and Counter Financing of Terrorism

26 February 2025

On 21 January 2025, the Urban Development Authority (“URA”) released a revised version of the Guidelines for Developers on Anti-Money Laundering and Counter Financing of Terrorism (Version 1.2) (“Guidelines”). 

In line with the key recommendations in the report by the Inter-Ministerial Committee on Anti-Money Laundering (“IMC”), the Guidelines have been updated to: 

  • clarify the requirements for developers to conduct customer due diligence (“CDD”) checks and ongoing monitoring of their purchasers; and 
  • provide more guidance on anti-money laundering (“AML”) practices such as identifying suspicious indicators and corroborating source of wealth/source of funds. 

The IMC was set up in November 2023 to review Singapore’s AML framework and make recommendations to strengthen defences against money laundering. In October 2024, the IMC released its report on key recommendations of its review, including proposed strengthening of AML gatekeeping standards so as to advance Singapore’s three-pronged AML strategy of Prevention, Detection, and Enforcement. 

A summary of the changes to the revised Guidelines is set out below: 

  • Require developers to perform CDD checks on the person(s) on whose behalf the purchaser (who is an individual) is acting. Previously, developers were required to perform CDD checks on the beneficial owner of a purchaser who was an entity or legal arrangement. This requirement will be expanded to cover the person(s) on whose behalf the purchaser (who is an individual) is acting. 
  • Updates to the existing list of suspicious indicators to provide clearer guidance for developers in the identification of suspicious transactions. Examples of additional indicators to flag include: 
    • purchasers who possess travel documents issued by countries known to offer citizenship by investment and residency by investment programmes, or countries flagged by the Financial Action Task Force; 
    • purchasers who purchased two or more properties within a short period of time;
    • third-party transactions without apparent connection or legitimate explanation.
  • Under enhanced CDD (“ECDD”) measures, developers are required to corroborate the source of wealth (“SOW”) and source of funds (“SOF”) of the purchaser. More guidance has been given to aid developers in performing SOW/SOF corroboration in cases where ECDD measures have to be performed. Examples include:
    • conducting triangulation checks against a few sources to ensure robustness; and
    • assessing any legitimate reasons for unavailability of documents for corroboration. 

Reference materials 

The revised Guidelines are available on this webpage of the URA website www.ura.gov.sg.