SINGAPORE Law and Practice Contributed by: Jason Lim, Sreenivasan Narayanan SC and Palaniappan Sundararaj, Sreenivasan Chambers LLC
Victims can assert proprietary claims over misappro - priated assets through constructive trusts. This will be done in relation to seized assets at the disposal inquiry after conclusion of criminal proceedings. Civil claims against parties holding assets can also be commenced. For example, where a fiduciary or agent receives a bribe, the bribe and its traceable proceeds are held on constructive trust for the principal, and can be recovered. Similarly, where a director or fidu - ciary misapplies or obtains the principal’s property, they hold it on trust for the principal. Singapore courts have applied these principles to recognise victims’ beneficial ownership of stolen or diverted assets and their proceeds, including in complex corporate frauds, and have ordered constructive trustees to account for value at the time of misappropriation or for substitu - tive equitable compensation. The same would apply to third parties in “knowing receipt” or guilty of “know - ing assistance”. 7. Enforcement Priorities and Case Law Developments 7.1 Enforcement Priorities Singapore’s current enforcement priorities in financial crime reflect a risk-based approach, with MAS and other enforcement agencies focusing on conduct that poses the greatest threat to the integrity and stability of Singapore’s financial system. The risk-based approach involves collaboration and co-ordination with government agencies working closely with one another and with the private sec - tor to identify, monitor and respond to evolving risks, trends and typologies. MAS’ risk assessments draw on observations from ongoing risk monitoring and surveillance efforts over the years. According to the MAS website, these risk assessments are published to strengthen the industry’s collective understanding of prevailing risks and to enable targeted prevention, detection and enforcement measures to be taken in a timely manner. 7.2 Recent Case Law and Latest Developments The decision of the Court of Appeal in Soh Chee Wen v Public Prosecutor [2025] 2 SLR 176 (the “Soh Chee
Wen (Conviction)”) represents one of the most signifi - cant cases in the area of market misconduct in Sin - gapore. The prosecution described the matter as the “most serious case of stock market manipulation in Singapore”. The case is notable for its clarification of the ele - ments of the offence of false trading and market rig - ging under Section 197 (1)(b) of the SFA. The charges were framed as criminal conspiracies under Section 120A of the Penal Code, and the court considered in detail the requirements for proving that the appellants had agreed to do acts with the intention of creating, or to engage in a course of conduct a purpose of which was to create a false appearance with respect to the market for or price of securities. Soh was sentenced to an aggregate of 36 years’ imprisonment and the co-accused, Quah, to 20 years’ imprisonment. The court noted the unprecedented scale of the scheme: it involved well over seven bil - lion trades, caused a loss in market capitalisation of approximately SGD7.8 billion, and resulted in approxi - mately SGD273 million in financial losses to the finan - cial institutions involved. Another recent case is Lim Oon Kuin v Public Prose - cutor [2026] SGHC 47. In this case, Lim Oon Kuin, the founder and managing director of Hin Leong Trading (Pte) Ltd (HLT), one of Singapore’s largest oil trading companies, was convicted after trial on three charg - es: two charges of cheating under Section 420 of the Penal Code and one charge of abetment of forgery for the purpose of cheating under Section 468 read with Section 109 of the Penal Code. This case addressed several important legal principles and the court clarified the legal elements of cheat - ing under Section 420 of the Penal Code. The court confirmed that the elements of the cheating charges required: (i) the practice of a deception on HSBC by Lim through HLT employees; (ii) that by such decep - tion, HSBC was induced to deliver property to HLT; and (iii) that there was dishonest intent on Lim’s part. The court also clarified the element of delivery – the court held that the crediting of the discounted sums into HLT’s current account constituted delivery of
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