Commentary: What Prince Group allegations tell us about how financial crime is evolving

New: You can now listen to articles.

This audio is generated by an AI tool.

SINGAPORE: After the United States seized over US$15 billion in bitcoin and issued sanctions in October against Prince Holding Group, the Cambodian group it accused of running a scam empire, other jurisdictions took actions of their own. Singapore seized S$150 million (US$115 million) in assets, with another US$150 million by Taiwan and US$354 million by Hong Kong. On Wednesday (Dec 3), Thailand announced it had seized more than US$300 million in assets linked to Prince Group and other scam investigations.

Yet beneath the numbers and headlines lies a more complex story of how transnational criminal organisations have evolved – and whether countries can tackle the new challenges they present.

The Prince Group allegations probably led many in Singapore to think back to the 2023 S$3 billion money laundering case, involving the so-called Fujian gang. But there are some fundamental differences.

That 2023 operation involved sequential crimes: Illicit proceeds generated overseas through scams and illegal gambling, then laundered through Singapore’s financial system. Investigators had to dig through a complex scheme involving forged passports, shell companies and draw links across a network of individuals, but there was a clear trail to follow: dirty money from foreign crimes flowing into luxury properties and bank accounts here.

The allegations against Prince Group and founder Chen Zhi paint a more sophisticated picture. In US filings and Department of Justice statements, prosecutors alleged that Prince Group itself generated vast proceeds by operating forced-labour scam compounds in Cambodia, where trafficked workers carried out “pig butchering” cryptocurrency investment fraud. 

They further alleged that the enterprise used a web of affiliated businesses and ostensibly legitimate corporate vehicles across more than 30 countries, including 17 Singapore-registered entities listed in US Treasury designations, to hold assets, obscure ownership, move funds and provide commercial cover for the wider operation. 

In this model, the boundaries between criminal activity, business infrastructure and financial services blur, creating an integrated ecosystem rather than the clean sequence of “crime abroad, laundering in Singapore” seen in the Fujian gang case. 

If allegations are confirmed, this integrated structure creates detection challenges that sequential laundering does not.

RED FLAGS BECOME HARDER TO SPOT

There is an inherent difficulty to detecting crimes that exploit legitimate business characteristics. Traditional frameworks excel at identifying red flags: unusual patterns, mismatched income sources or sanctioned jurisdictions. 

But if companies use the same infrastructure to conduct actual business and facilitate offshore crimes, how can investigators determine which parts are criminal activity? Flags turn an ambiguous shade of red.

Investigators must look beyond transaction patterns to question underlying business models. The challenge intensifies when serious crimes – forced labour camps, trafficking, violence – occur entirely outside Singapore.

Local financial institutions do not screen for forced labour indicators in overseas compounds; they assess whether financial behaviour raised concerns of money laundering taking place here. 

This does not suggest inadequate frameworks. Rather, it shows criminal innovation outpacing categorical approaches. Detection of transnational crime requires cross-border intelligence sharing and analytical capacity to connect disparate indicators.

Indeed, the Singapore Police Force (SPF) said it received related intelligence on suspicious transactions related to Prince Group in 2024 and engaged foreign counterparts to this end. More coordinated action came only after US and UK authorities published their findings on Oct 14.

POST-REFORM COORDINATION IN ACTION

Singapore’s response to the Prince Group allegations demonstrates that the reforms introduced in the wake of the S$3 billion money laundering case are functioning. 

Following that August 2023 case, an inter-ministerial committee was established in November that year to review Singapore’s AML framework. This led to the establishment of the Anti-Money Laundering Case Coordination and Collaboration Network (AC3N) in late 2024, led jointly by SPF’s Commercial Affairs Department and the Monetary Authority of Singapore. 

After US and UK authorities disclosed their findings, Singapore moved within 16 days to seize S$150 million in assets, including properties, bank accounts, a yacht and 11 cars.

This coordination matters for faster decision-making and better intelligence sharing. 

The AC3N brings together sector supervisors, law enforcement, and intelligence agencies – traditionally siloed entities. Supporting this will be NAVIGATE, a whole-of-government data sharing interface that allows agencies to screen across databases for money laundering risks. Financial institutions’ proactive measures, including account closures, prevented larger sums from entering our system.

Yet coordination cannot eliminate the fundamental tension all global financial centres face: What attracts legitimate business to Singapore, London, New York or Hong Kong, also attracts criminals seeking to legitimise illicit proceeds.

“TOO BUSINESS-FRIENDLY” CRITICISMS MISUNDERSTAND THE POINT

Do visible enforcement actions deter money launderers, or perversely signal that exploiting Singapore’s systems would provide the best veneer of legitimacy?

The answer is likely both. For unsophisticated criminals, convictions and forfeitures send clear deterrent messages. 

But transnational organisations with resources to build elaborate corporate facades make different calculations. They see rule of law, political stability, sophisticated infrastructure – and build complex schemes exploiting time lags in cross-border investigations. This creates an arms race.

Singapore cannot retreat to closed-door policies without undermining our economic model. The best alternative is keep strengthening its prevention and detection mechanisms.

Critics sometimes argue that Singapore’s business-friendly environment enables money laundering. This misunderstands the dynamics. 

From a capital markets perspective, Singapore faces the opposite criticisms – being over-regulated, with compliance requirements deterring listings and increasing costs. The challenge is not insufficient vigilance, but that any regime balancing openness with security faces exploitation by determined criminals.

The relevant question is whether our response mechanisms improve faster than criminal methods.

THE LONG ROAD AHEAD

Several realities bear acknowledging. Asset seizure is not asset forfeiture: When criminal syndicates and activities are outside Singapore’s jurisdiction, permanent recovery will be lengthy. 

Recent legislative reforms have eased prosecutorial burdens. Under the Anti-Money Laundering and Other Matters Act 2024, prosecutors need only show that the accused “knew or had reasonable grounds to believe” they were dealing with criminal proceeds, without having to trace every dollar back to a specific predicate crime. But cross-border complexities remain substantial.

More broadly, financial crime is changing. Traditional categories – money laundering, fraud, trafficking – increasingly converge within single enterprises. 

The evolution of Singapore’s frameworks is underway. But as long as Singapore remains a premier financial centre, it will continue being targeted by sophisticated networks.

The measure of success is not eliminating money laundering entirely. It is ensuring our detection and response capabilities evolve as fast as criminal methods. On that measure, recent actions suggest Singapore is moving in the right direction.

Ben Chester Cheong is a law lecturer and MOE-Start scholar at the Singapore University of Social Sciences. He is Visiting Fellow in Law at Reading and Associate Academic Fellow at NUS Asia-Pacific Centre for Environmental Law. He is also a lawyer at RHTLaw Asia.