Murali Pillai
3 min readNov 2, 2022

Globally, real estate properties have been a favoured asset class of money launderers. There are several countries, including the UK, which specifically require all overseas entities owning real properties to make disclosure of the particulars of the ultimate beneficial owners and principal officers. I, therefore, asked whether the Ministry of Law has similar plans. I also asked whether the Ministry of Law will consider making available to the public information of beneficial ownership of shell companies that own properties. In her reply, SPS Rahayu Mahzam stated that her Ministry will consider my suggestion on making public the information of beneficial ownership. What ought to be noted, as a matter of background, is that, currently, foreign companies which just own property don’t have to be registered with ACRA. My PQ and SPS Rahayu’s response may be accessed below.

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Mr Murali Pillai asked the Minister for Law whether the Ministry will require overseas entities wanting to buy, sell or transfer properties in Singapore to register with the Accounting and Corporate Regulatory Authority and disclose the beneficial owners and principal officers of the entities along the lines of what has been introduced in United Kingdom in August 2022 as a measure against money laundering.

The Senior Parliamentary Secretary to the Minister for Law (Ms Rahayu Mahzam) (for the Minister for Law): Mr Deputy Speaker, the Member has asked if there should be a requirement for overseas entities to register with the Accounting and Corporate Regulatory Authority (ACRA) before they can transact in property in Singapore.

I understand that ACRA has implemented a register of registrable controllers for companies, foreign companies and limited liability partnerships (LLPs). Such entities are required to file information on their registrable controllers, that is, beneficial owners, centrally with ACRA. This serves to make the ownership and control of such entities more transparent and thus reduce opportunities for the misuse of such entities for illicit purposes. Foreign entities that carry on or intend to carry on business in Singapore are already required to be registered with ACRA and would be subject to existing requirements to file information on their beneficial owner with ACRA.

Currently, in line with the anti-money laundering and countering the financing of terrorism standards set by the Financial Action Task Force, professionals involved in the buying, selling, and transfer of real estate, such as real estate agents and lawyers, are required to address the money laundering and terrorism financing risks. They have to assess their money laundering and terrorism financing risks, conduct customer due diligence including the identification of their customers’ beneficial owners, and where the risks of a customer are high, take enhanced measures such as the source of funds checks.

Agencies are assessing whether a measure like the UK’s Register of Overseas Entities would be useful in our context.

Mr Deputy Speaker: Mr Murali Pillai.

Mr Murali Pillai (Bukit Batok): I thank the hon Senior Parliamentary Secretary for her answer. My supplementary question is as follows: whether MinLaw would be intending to make the information on beneficial ownership of shell companies which own properties, accessible by the public as well as financial institutions and professionals who act as gatekeepers, so they can do their customer due diligence better.

Ms Rahayu Mahzam: I note the underlying concerns in relation to the Member’s suggestion. Let us take this back and consider whether this is something feasible in our context.



Murali Pillai

Member of Parliament, Bukit Batok SMC, Advisor to Bukit Batok SMC GROs.