Billion-dollar money laundering case: 4 law firms linked to seized properties named, 2 more identified and reprimanded

SINGAPORE: Four law firms that breached their anti-money laundering obligations over the purchase of properties in the S$3 billion (US$2.3 billion) money laundering case have been named, following the conclusion of investigations into their cases.

In an update on Friday (Aug 1), the Ministry of Law (MinLaw) said it had completed the regulatory action related to the four law firms - Anthony Law Corporation, Fortis Law Corporation, Legal Solutions LLC and Malkin & Maxwell LLP. 

As such, MinLaw added it was now able to furnish more details on their conveyancing of the real estate properties seized as part of the anti-money laundering operation in August 2023. Conveyancing refers to the legal process of transferring the ownership of a property from one person to another.

Their penalties were previously made known on Jul 15, but MinLaw then did not name the four firms.

It then said 24 law practices were involved in investigations by Singapore's director of legal services (DLS) Sarala Kumari Subramaniam, supported by MinLaw, and 11 of the probes had been concluded.

As of Jul 31, 13 of the 24 law practices had been dealt with, the ministry said on Friday. 

Two more law firms - William Poh & Louis Lim, now known as Louis Lim & Partners, and Templars Law LLC were also named, as inquiries and regulatory action had concluded, it added.

With 13 of the probes having concluded, MinLaw also identified five lawyers involved in the conveyancing of the seized real estate properties. 

They are: Mr Tan Chau Chuang, Mr Andrew Wong Wei Kiat, Mr Tan Tse Chia Patrick, Mr Ee Tian Huat Patrick and Mr Poh Tian Hock William.

All have been referred to the Law Society to "consider if there are grounds for further professional disciplinary action against these lawyers".

MinLaw previously said on Jul 15 that one lawyer had been referred to the Law Society for disciplinary action, without naming the individual. While a Law Society spokesperson then confirmed that the lawyer had been referred to it for disciplinary action, it was unable to reveal the identities of those involved.

In response to the latest developments, the Law Society again told CNA: "As the referral relates to disciplinary matters, such proceedings are confidential."

ENFORCEMENT ACTION TAKEN

All law practices and lawyers are subject to anti-money laundering obligations under the Legal Profession Act 1966. 

These include performing an adequate analysis of the risks of money laundering in relation to each client and performing customer due diligence measures that are in line with a client’s risk profile.

Lawyers and law firms also have to file a suspicious transaction report with the police if they have reasonable grounds to suspect that a client might be engaged in money laundering.

Expanding on the enforcement action taken, the ministry said Anthony Law Corporation had acted for nine clients to convey 25 properties valued at around S$135 million in total. 

According to MinLaw, its breaches included inadequate scrutiny of the transactions, which was not commensurate with the clients’ and transactions’ money laundering risks.

"Anthony Law Corporation did not corroborate or verify the clients’ explanations for why the transactions were being funded by seemingly unrelated third parties, even though these were red flags," it said. 

The firm also failed to comply with documentation requirements. 

If a law practice or lawyer decides to continue to act for the client despite suspicions of money laundering, they must substantiate and document the reasons for this and adopt commensurate risk mitigation measures, including enhanced customer due diligence and monitoring measures.

However, while Anthony Law retained and continued to undertake transactions for some of these clients despite filing suspicious transaction reports against them, it did not substantiate or document its reasons for why it had considered it appropriate to do so, said MinLaw.

The firm was ordered to pay a financial penalty of S$100,000. One of its lawyers, Mr Tan Chau Chuang, has since been referred to the Law Society. 

Fortis Law Corporation acted for 16 clients to convey 55 properties valued at around S$398.7 million in total.

The firm did not conduct checks to verify the clients’ claims that the payments for the transactions were indeed from legitimate remittance companies, said MinLaw. 

As a result, it was handed a financial penalty of S$30,000 and two lawyers - Mr Wong and Mr Tan Tse Chia Patrick - were referred to the Law Society.

Mr Wong is no longer practising with Fortis Law. 

Both Anthony Law and Fortis Law have paid the financial penalty, MinLaw noted. 

Legal Solutions LLC, the third firm to receive a financial penalty, acted for two clients to convey 20 properties valued at around S$117 million in total.

“It did not adequately document the details of its analysis of the clients’ money-laundering risks,” said the ministry. 

"It also did not perform all the required enhanced customer due diligence measures after it filed a suspicious transaction report, such as documenting its internal discussions on, and reasons for, retaining the clients despite filing the suspicious transaction report." 

Legal Solutions has been ordered by Ms Subramaniam to pay a financial penalty of S$70,000, while a lawyer, Mr Ee, has been referred to the Law Society. He no longer practices at the firm. 

Meanwhile, Malkin & Maxwell LLP has been reprimanded to remind it to be mindful of its anti-money laundering obligations and responsibilities. 

MinLaw said it was taken into consideration that the firm had acted for one client to convey one property valued at around S$40 million. 

Inquiries revealed that while Malkin & Maxwell conducted checks into the client’s source of funds, its independent checks were "not sufficiently in-depth". 

Instead, it relied unduly on checks that it assumed third parties would have done on its client.

William Poh & Louis Lim and Templars Law LLC were also reprimanded by Ms Subramaniam to remind them to be mindful of their anti-money laundering obligations and responsibilities. 

Mr Poh, a lawyer who previously worked at William Poh & Louis Lim before joining Templars Law, has been referred to the Law Society.

According to MinLaw, Mr Poh was the managing partner and sole partner-in-charge of conveyancing matters at William Poh & Louis Lim until around May 2023. 

During his time at the firm, he commenced transactions for six clients to convey 32 properties valued at around S$246.7 million in total. 

Twenty-six of those property transactions concluded while Mr Poh was practising with William Poh & Louis Lim, said MinLaw.

The lawyer later left the firm in or around May 2023 to join Templars Law, and his previous firm amended its name to Louis Lim & Partners after his departure.

Mr Poh brought the remaining six property transactions to Templars Law and concluded the transactions soon after in June 2023, said MinLaw. 

Some of the breaches observed by Ms Subramaniam included not obtaining certain documents as part of customer due diligence, not adequately scrutinising the clients’ and transactions’ money-laundering risks and not applying commensurate risk mitigation measures. 

Mr Louis Lim, managing partner at Louis Lim & Partners, told CNA on Saturday that he had no involvement with the transactions that were handled by Mr Poh.

"The property transactions … were all conducted by the firm's former partner Poh Tian Hock William," he said.

"I do not at all know the clients involved in the reported case. I was also totally not involved in the said property transactions involving the reported persons," he added.

Mr Lim also said that he had not been personally involved in conveyancing matters since about 2008, and that he and Mr Poh had been operating from separate locations for several years prior to Mr Poh's departure from William Poh & Louis Lim.

Templars Law LLC's director, Mr Steven Lam, told CNA on Monday that Mr Poh was still with the firm. 

"As this matter is currently under confidential investigations and review by the relevant regulatory body, we are unable to comment further at this time," he added. 

Anthony Law's managing director Anthony Lim also said on Monday that the firm would not be commenting on MinLaw's actions at this stage. However, he told CNA that Mr Tan Chau Chuang is still with the firm, albeit in a different role from the one he held previously.

Fortis Law's founder and CEO Patrick Tan told CNA on Thursday that the firm acknowledged the findings of the Legal Services Regulatory Authority, a department under MinLaw.

"The firm has cooperated fully with the authorities during the inquiry, and has implemented measures to enhance internal policies, procedures, and controls and strengthened our client onboarding and monitoring processes." 

Mr Tan added that his firm remains strongly committed to the highest standards of governance, in order to prevent money laundering and safeguard the integrity of Singapore’s legal industry.

CNA has also sought comment from the other firms identified by MinLaw.

HOW REFERRALS TO THE LAW SOCIETY ARE HANDLED

A lawyer who breaches his or her anti-money laundering obligations is liable, among other things, to face disciplinary proceedings.

“Lawyers whom the director of legal services has referred to the Law Society will be subject to the disciplinary proceedings process and framework in the Legal Profession Act,” said MinLaw. 

Under this framework, each lawyer’s case will undergo further fact-finding by the relevant committee or tribunal to assess if there have been breaches, and if so, the lawyer’s individual culpability and any appropriate disciplinary action and penalties against him or her. 

This disciplinary process is separate from the director of legal services’ inquiries and enforcement actions against the law practices. 

“We urge the public to refrain from speculating or sharing unverified information while the process is ongoing,” said MinLaw. 

The billion-dollar money-laundering case involved millions of dollars earned over the years from an illicit gambling ring with Southeast Asian bases, and that was aimed at punters in China.

Investigations into the transnational case date back to 2021 and culminated in islandwide police raids in August 2023.

Singapore police seized luxury cars, watches, jewellery, designer goods, cryptocurrency and cash. 

More than 150 properties were also seized, including homes in Singapore’s most upmarket neighbourhoods.

The fees that Anthony Law, Fortis Law, Legal Solutions, Malkin & Maxwell, William Poh & Louis Lim and Templars Law collected in total from acting for their clients for these property transactions ranged from S$15,000 to around S$170,000, said MinLaw.

"In imposing the financial penalties, alongside other regulatory measures that include following up with these law practices on their remedial measures to strengthen compliance with anti-money laundering obligations, the DLS aims to ensure that law practices in Singapore observe their anti-money laundering obligations and keep Singapore a clean and money-laundering-free business- and financial-hub," it added.

The ministry also said probes into the remaining 11 law practices are ongoing and more information will be provided after the remaining inquiries and enforcement actions are completed.