Samlit Moneychanger Pte. Ltd. (“Samlit”) will be charged in court on Thursday, 9 July 2026 with 19 counts of failure to comply with a direction
Background
2. On 23 February 2024, the SPF and the Monetary Authority of Singapore (“MAS”) jointly commenced investigations into Samlit’s Director and Compliance Manager. The investigations followed reports that beneficiaries in China were unable to access monies that were remitted through Samlit because they had been frozen or confiscated by authorities in China, as well as Samlit’s abrupt surrender of its payment services licence with the intention of discontinuing its business during an ongoing inspection by MAS
Obstruction of Investigations
3. During investigations, the Compliance Manager interfered with SPF’s access to two email accounts used by Samlit, obstructing SPF’s investigation efforts. In connection with this, SPF will be charging the Compliance Manager with the offence of obstruction of justice under Section 204A(b) of the Penal Code. This offence carries an imprisonment term of up to seven years, a fine, or both.
4. Between 24 February 2024 and 30 August 2024, SPF issued the Compliance Manager with 20 orders under Section 39 of the CPC, requiring him to provide passwords and authentication access to the seized devices and email accounts for the purpose of investigations, which he did not comply with. In connection with these orders, the SPF will be charging Samlit’s Compliance Manager with 20 counts of failing to comply with an order to assist the SPF to access computers, under Section 39(3) of the CPC. These offences each carry an imprisonment term of up to six months, a fine up to S$5,000, or both.
5. The SPF takes a serious view of any attempt to obstruct the course of justice including acts which impede law enforcement investigations. All persons are required to comply with lawful orders issued by law enforcement officers in the course of their investigations. The SPF will not hesitate to take action against any individual who attempts to hinder or obstruct its investigations.
Failures in Complaints Handling
6. In view of the number of reports against Samlit, MAS issued a direction on 22 February 2024 under Section 102(1) of the Payment Services Act 2019 requiring Samlit to continue assisting and addressing complaints by affected remitters. This included providing the affected remitters with relevant remittance information to facilitate their appeals to law enforcement agencies in China regarding the freezing of monies in their beneficiaries’ accounts.
7. In connection with this, MAS will be charging Samlit with offences for failing to comply with this direction under Section 52(3) of the MAS Act and Section 61(3) of the FSMA. MAS will also be charging Samlit’s Director and its Compliance Manager with offences under Section 61(3) read with Section 174(2) of the FSMA.
8. Each failure to comply with a MAS direction is an offence punishable under Section 52(3) of the MAS Act and Section 61(3) of the FSMA where the person is liable on conviction to a fine not exceeding $1 million.
9. In 2024, MAS took steps to secure the funds in Samlit’s corporate bank accounts, given the circumstances surrounding Samlit’s sudden surrender of its licence. MAS’ direction remains in force until, among other conditions, Samlit obtains a certificate by an external auditor confirming that it has made sufficient provisions for liabilities, including any legal liabilities.
Fraudulent Trading
10. As part of the investigations, the Police looked into possible offences of fraudulent trading. The investigation findings till date did not reveal sufficient evidence for criminal charges under Section 238(4) of the Insolvency, Restructuring and Dissolution Act. The Police, in consultation with the Attorney-General’s Chambers, will be taking no further action at this point. This does not preclude further investigation if Police receive new material information or evidence.
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[1] A direction details specific instructions to a specified person or classes of persons to comply with certain requirements. Such direction has legal effect and non-compliance may constitute a criminal offence.
[2] Refer to SPF and MAS Joint Statement dated 23 Feb 2024 “Two Investigated for Suspected Fraudulent Trading and Suspected Failure to Comply with Obligations as a Licensed Payment Services Provider”.
