INSTITUTIONAL FRAMEWORK AND PRACTICAL DEVELOPMENTS IN
ANTI-CORRUPTION: PERSPECTIVES FROM SINGAPORE’S EXPERIENCE IN
COMBATING CORRUPTION
Siong Leng Neo*I. INTRODUCTION
Singapore is well regarded globally as one of the few countries in the world with a low
incidence of corruption. In 2016, Transparency International’s Corruption Perceptions Index(TI-CPI) ranked Singapore as the 7th least corrupt country in the world and the least corrupt
Asian country with a score of 84 out of 1001. The Political and Economic Risk Consultancy(PERC) also ranked Singapore as the least corrupt country in Asia in 2016 2 , a position
Singapore held since 1995. The results of a recent Public Perception Survey conducted from
May to June 2016 to measure the general public’s perception on the level of corruption in
Singapore, understanding of corruption and awareness of the Corrupt Practices Investigation
Bureau’s (CPIB) work showed that fewer respondents perceived corruption as common in
Singapore as well as in the public and private sectors in 2016 (24%) compared to 2013 (34%).
Almost 90% of the respondents rated Singapore positively on its efforts in controlling thecorruption situation in the country in 20163.
II.

AN INSTITUTIONAL PERSPECTIVE – SINGAPORE’S CORRUPTIONCONTROL FRAMEWORKOver the years, Singapore has established an effective anti-corruption framework,
which has seen it transform from a country rampant with corruption to one of the least corrupt
countries in the world. Singapore’s strategy on anti-corruption can be illustrated through thefollowing diagram, which consists of four pillars of corruption control, underpinned by strong
political will.

Diagram: Singapore’s corruption control framework
Senior Assistant Director, General Investigations Branch 2, Corrupt Practices Investigation Bureau, Singapore.
Refer to: https://www.transparency.org/news/feature/corruption_perceptions_index_20162
Refer to: https://www.cpib.gov.sg/research-room/political-economic-risk-consultancy
3
Refer to: https://www.cpib.gov.sg/sites/cpibv2/files/CPIB_Annual%20Report_2016.pdf*
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A.

Political Will
The political will to eradicate corruption was established by Singapore’s founding
Prime Minister, Mr Lee Kuan Yew, when the People’s Action Party (PAP) was elected into
government in 1959. The PAP was determined to build an incorruptible and meritocratic
government and took decisive and comprehensive action to stamp out corruption from all levelsof Singapore’s society. As a result of the government’s unwavering commitment andleadership, a culture of zero tolerance against corruption became ingrained in the Singaporean
psyche and way of life.
B.

Effective Laws
Singapore relies on two key legislations to fight corruption; the Prevention of
Corruption Act (PCA), and the Corruption, Drug Trafficking and Other Serious Crimes(Confiscation of Benefits) Act (CDSA). The PCA has a wide scope which applies to persons
who give or receive bribes in both the public and private sector. The CDSA, when invoked,
confiscates ill-gotten gains from corrupt offenders. Together, the two laws ensure that
corruption remains a high-risk low-rewards activity. Upon the conclusion of investigations by
the CPIB, all alleged corruption cases will be handed over to the Attorney-General’s Chambers(AGC), which is responsible for prosecuting criminal offences in Singapore, for legal
assessment of the available evidence before deciding whether to charge the accused person(s)formally in Court. Any direction to charge an accused person under the PCA or CDSA mustbe accompanied with a consent in writing from the Public Prosecutor.
C.

Independent Judiciary
In Singapore, an independent judiciary provides insulation from political interference.
The Chief Justice is appointed by the President on advice from the Prime Minister and theCouncil of Presidential Advisers. District judges and magistrates are appointed by the President
with advice from the Chief Justice. Various provisions of the Constitution also guarantee theindependence of the Supreme Court judiciary. Transparent and objective in its administrationof the rule of law, the judiciary recognises the seriousness of corruption and adopts a stance ofdeterrence by meting out stiff fines and imprisonment towards corrupt offenders.
D.

Effective Enforcement
The CPIB is the only agency authorised to investigate corruption offences under thePrevention of Corruption Act (Chapter 241) and other related offences. It is a government
agency under the Prime Minister’s Office, operating with functional independence and ishelmed by a director who reports to the Prime Minister. The CPIB acts swiftly and vigorously
to enforce the tough anti-corruption laws impartially for both public and private sector
corruption. During the investigation process, the CPIB will work with various government
agencies and private organisations to gather evidence and obtain information.
E.

Responsive Public Service
The Singapore Public Service is guided by a Code of Conduct, which sets out the highstandards of behaviour expected of public officers based on principles of integrity,
incorruptibility and transparency. The practice of meritocracy in the Public Service, together
with regular reviews of administrative rules and processes to improve efficiency also reduce
the opportunities for corruption. The CPIB is mandated to conduct procedural reviews forgovernment agencies which may have work procedures that can be exploited for corrupt
practices.

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III. PRACTICAL DEVELOPMENTS – NEW INITIATIVES AND MEASURES
While Singapore’s corruption control framework provides a solid foundation for
combatting corruption, this framework is continually being complemented by new initiatives
and measures to adapt to the changing risks posed by corruption.
A.
1.

Public Sector Measures
Enhanced Rules on Local Casino Visits
From 1 October 2013, all public officers who have visited local casinos or purchased
an annual pass are required to make a declaration within seven working days. Public officers
who are exposed to higher risks of being bribed (i.e. police officers, senior public officers
whose misconduct will have significant reputational risks to the public service) are required todeclare every casino visit.
2.

Mandatory Job Rotation and Mandatory Block Leave
From 1 January 2014, public officers who are exposed to a higher risks of being bribed(i.e. those handling procurement or market sensitive information) are not allowed to serve inthe same position for more than five years. These officers are subjected to mandatory job
rotation and mandatory block leave.4
3.

CPIB’s Investigation Policy Unit (IPU)
In 2014, CPIB formed the Investigation Policy Unit (IPU) to enhance the investigation
policy framework of CPIB. The unit is responsible for upholding the integrity of CPIB’s
corruption database, crafting investigation policies to address deficiencies uncovered inorganisations during investigations as well as analysing data to detect any emerging corruption
trends associated with any specific industry so that CPIB can intervene with enforcement or
prevention measures to nip corruption in the bud.5 A deeper dive into the statistics analysed by
IPU in 2016 revealed that there were two particular areas for CPIB to strengthen our anticorruption efforts, namely, that of private sector employees prosecuted in court for corruption
related offences emanating from maintenance work as well as the wholesale and retailbusiness.6
4.

CPIB’s Point of Contact Initiative
As part of CPIB’s efforts to strengthen the civil service governance and reporting
framework, CPIB launched the Point of Contact (POC) Initiative in 2016 to establish andenhance links with government agencies and statutory boards. Each CPIB officer served as acontact point with a government agency and/or statutory board in terms of offering advice orassistance on corruption prevention matters and serving a feedback channel to CPIB. Somefunctions of the POC include the arrangement for anti-corruption activities, such as prevention
talks and ethics day, assisting in the development of integrity management programmes andreceiving referrals on corruption offences within these agencies/statutory boards.

Refer to https://www.psd.gov.sg/press-room/speeches/speech-by-deputy-prime-minister-teo-chee-hean-atcommittee-of-supply-2014
5
Refer to: https://www.cpib.gov.sg/about-us/our-work/organisational-structure
6
Refer to: https://www.cpib.gov.sg/sites/cpibv2/files/CPIB_Annual%20Report_2016.pdf
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B.
1.

Private Sector Measures
Launch of the Singapore Standard (SS) ISO 37001 on Anti-Bribery Management
Systems
In April 2017, CPIB and SPRING Singapore7 co-launched the Singapore Standard (SS)ISO 37001 on Anti-bribery Management Systems8 aimed at helping companies strengthen theiranti-bribery systems and processes in reducing risk and costs relating to bribery as well as
ensuring compliance with anti-bribery laws. The SS ISO 37001 specifies requirements for top
management leadership and commitment, anti-bribery policies and procedures, risk
assessments, reporting, monitoring and investigation procedures, among several otherrequirements. SPRING Singapore and the Singapore Accreditation Council9 are also working
on an accreditation scheme for certification bodies to provide SS ISO 37001 certification
services by the end-2017. It is hoped that the SS ISO 37001 certification will provide
Singapore companies a competitive edge over foreign firms in assuring customers andsuppliers that their companies have good anti-bribery practices that were in line with global
best practices.
2.

PACT: A Practical Anti-Corruption Guide for Businesses in Singapore
CPIB developed an easy to comprehend guidebook titled PACT: “A Practical AntiCorruption Guide for Businesses in Singapore” to assist business owners to implement an anticorruption system within their companies. PACT’s four-step framework is as follows:10(i)Pledge - Companies are encouraged to implement their own anti-corruption
policy and to create a code of conduct that employees can refer to in orderto safeguard themselves from falling foul of the law;(ii)
Assess - Companies are encouraged to identify areas of high corruption risks
and to conduct periodical risk assessments focusing on vulnerable job
functions and processes;(iii) Control & Communicate - Companies are encouraged to keep accurate
records and having clear operating procedures, with audit checks carried out
periodically as well as a robust reporting or whistle-blowing systems.
Companies should communicate the anti-corruption policy, code of conduct,
internal control and reporting system to all its employees, business partners
and other stakeholders, if any;(iv)
Track – Companies are encourage to review their company’s anti-corruption
systems in a timely manner following company re-organisation, expansion
in operations, new legal/national/international anti-bribery standards, andshifts in the business operating environment.

SPRING Singapore is an agency under the Ministry of Trade and Industry responsible for helping Singapore
enterprises grow and building trust in Singapore products and services. As the enterprise development agency,
SPRING works with partners to help enterprises in financing, capability and management development,
technology and innovation, and access to markets. As the national standards and accreditation body, SPRING
develops and promotes an internationally-recognised standards and quality assurance infrastructure.
8
The (SS) ISO 37001 was Singapore’s adaptation of ISO 37001 Anti-Bribery Management Systems that was
launched on 15 October 2016. CPIB had led the working group from Singapore in the negotiation of the ISO
37001.
9
The Singapore Accreditation council (SAC) is the national authority for the independent accreditation ofconformity assessments services, such as testing, calibration, certification and inspections. The industry-led SAC
is manage under the aegis of SPRING Singapore.
10
Refer to: https://www.cpib.gov.sg/sites/cpibv2/files/PACT%20A%20Practical%20AntiCorruption%20Guide%20For%20Businesses%20in%20Singapore.pdf
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C.

Public Education and Community Outreach Efforts
As part of the CPIB’s public education and community outreach efforts to spread its
anti-corruption message, CPIB initiated the following initiatives in recent years:
1.

CPIB Open House in conjunction with International Anti-Corruption Day
On 9 December 2012, CPIB held its first open house, which coincided with theInternational Anti-Corruption Day. Members of the public had the opportunity to tour CPIB’s
premises, attend educational talks and guided heritage tours promulgating corruption issues
and the pitfalls of corruption.11
2.

“Unite Against Corruption: You are the Solution” Road Show
On 13 December 2014, CPIB held an annual road show titled “Unite Against
Corruption, You are the Solution” at the Toa Payoh Hub Mall Atrium. A wide range ofactivities, including a skit, games and quizzes were organized to educate the public on the topic
of corruption. There was also an exhibition giving the public a glimpse of CPIB’s history as
well as significant cases that CPIB had dealt with.12 At the roadshow, CPIB also took presented
awards to 35 winners from secondary and tertiary institutions, who participated in CPIB “Unite
Against Corruption” video competition.

3.

Roving Exhibition and Mobile Application
On 7 April 2016, Prime Minister Lee Hsien Loong launched CPIB’s first ever roving
exhibition and mobile heritage trail application titled “Declassified: Corruption Matters” and“The Graftbusters Trail” respectively, at the National Library. The exhibition featured CPIB’s
declassified case archives and illustrated the transformation of corruption-ridden Singapore in
the early days to its current status of being one of the least corrupt countries in the world. The
exhibition subsequently roved to other regional libraries as well as to tertiary institutions. “The
Graftbusters Trail” mobile application featured seven prominent landmarks that had witnessed
the development and establishment of key legislative and operational measures in the fightagainst corruption. Users can unlock a quiz while visiting each landmark to learn about
Singapore’s experience in combatting corruption.13
4.

Corruption Reporting and Heritage Centre
The CPIB’s Corruption Reporting and Heritage Centre (CRHC) was officially opened
by Prime Minister Lee Hsien Loong on 6 June 2017. Located close to the city, the CRHC
allows members of public to report corruption complaints in a more convenient and discreet
manner. The CHRC also houses a heritage gallery, where members of the public can learn
about corruption matters through interactive multimedia gallery tours, featuring oral interviewsof past and present CPIB officers and preserved case exhibits and artefacts.14
D.

International Engagement
The CPIB is a founding member of the new international Anti-Corruption Coordination
Centre (IACCC) launched in July 2017 alongside other law enforcement agencies from
Australia, Canada, New Zealand, the UK and the US. The IACCC serves to improveinformation sharing and coordinate law enforcement actions between law enforcement officers
from respective countries by gathering together in a single location to combat grand corruption.
Participation in the IACCC strengthened Singapore’s existing framework for international

Refer to: https://www.cpib.gov.sg/press-room/events/cpib-open-house
Refer to: https://www.cpib.gov.sg/press-room/press-releases/unite-against-corruption-you-are-solution
13
Refer to: https://www.cpib.gov.sg/trailapp
14
Refer to: https://www.cpib.gov.sg/press-room/events/corruption-reporting-heritage-centre
11
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cooperation with foreign law enforcement agencies, given that corruption has become
increasingly transnational in nature, which severely affects national interests.15
III.

CASE STUDIESSingapore’s corruption control framework and cross-cutting anti-corruption initiatives
aim to make the environment for committing a corrupt act in Singapore one of high risk andlow reward. Despite these measures, however, there are some who opportunistically seek totest the system. The following case studies demonstrate the robustness of Singapore’s anticorruption system against those who seek to test the system:
A.

Rejection of Bribes by Public Officers
In 2013, two police officers interviewed the occupants of a lodging house in the
Geylang vicinity as part of Singapore Police Force (SPF) efforts to detect vice activity. During
the interview, one of the occupants, a female Chinese National, offered a S$50 note to one
police officer, and subsequently offered the rest of her monies in her handbag to another police
officer so that both officers would not arrest her for immigration related offences. However,both officers rejected the bribes and the case was subsequently referred to CPIB for
investigations. The accused was shortly charged and sentenced to 10 weeks’ imprisonment.16
This case was a positive demonstration of the value of integrity and incorruptibility among
Singapore public officers.
B.

Inter-agency Cooperation on GST Tourist Refund Scheme Fraud
In 2013, the Inland Revenue Authority of Singapore (IRAS), using its data analytics
tool, detected several suspicious GST refund claims via its electronic Tourist Refund Scheme,(“eTRS”)17. Subsequent investigations by IRAS, Singapore Customs and CPIB uncovered thaton various occasions between January 2013 and January 2014, four Indian National tourists
made fraudulent claims amounting to $493,858.67 in GST refunds with the assistance of a
Customs officer, who received bribes amounting to $11,400 for approving these GST refund
claims.18

During the period of offence, the four Indian nationals bought receipts from genuine
shoppers who had purchased jewellery and obtained eTRS tickets from the jewellery retailers.
Thereafter, they approached the Customs officer who was on-duty at the airport’s inspection
counter and presented the jewellery as well as the eTRS tickets to him to support their GST
refund claims. The Customs officer went on to approve the GST refund claims despite the factthat the jewellery did not match the goods description shown on the eTRS tickets. The fourIndian nationals presented the eTRS notification slips at the Central Refund Counter, locatedin the airport’s departure transit lounge. After receiving the GST refunds in cash, the four
Refer to: https://www.cpib.gov.sg/press-room/press-releases/cpib-and-international-authorities-launchmultinational-centre-fight16
Refer to: https://www.cpib.gov.sg/case-studies/stories-integrity/zero-tolerance-bribery>
17
Tourists can claim GST refund on goods they have purchased and brought out of Singapore. A person who did
not purchase the goods and yet sought or obtained a GST refund under the tourist refund scheme would havecommitted an offence under the GST Act. Under eTRS, a tourist receives a receipt of goods purchased and an
eTRS ticket when he buys goods from a GST-registered retailer participating in eTRS. The tourist then uses theeTRS ticket or the credit card with which he purchased the goods to make a GST refund claim via the eTRS selfhelp kiosk at the Changi airport. As a control measure, physical inspection of the goods may be carried out at the
GST refund counter by Singapore Customs officers before a GST refund claim is approved.
18
Refer to: https://www.iras.gov.sg/irashome/News-and-Events/Newsroom/Tax-Crime/2014/Four-Men-Finedand-Sentenced-to-Jail-for-Fraudulent-GST-Tourist-Refund-Claims/
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Indian nationals spent a portion of the criminal proceeds on duty-free items, before departing
Singapore for India on the same day with the remaining proceeds.19
Although the usage of data analytics tools by IRAS helped to uncover suspicioustransactions, the accused persons would not have been successfully apprehended without theclose collaboration between government agencies. The Singapore Customs provided CPIB
with the background information, which CPIB leveraged on to gather the evidence ofcorruption during investigations. Additionally, the Immigration & Checkpoints Authority ofSingapore provide valuable information on the travel patterns of the four Indian Nationals.
V. GOING FORWARD
Over the past decade, we have observed changes in the modus operandi of corrupt
offenders moving away from the conventional manual records to easily concealed data storage
devices, thereby hampering investigators’ efforts to trace and prevent the dissipation of corrupt
proceeds. The increasing ease of performing financial transactions, known as FAST fundtransfers20, and the possibility of overseas FAST fund transfers being available in the near
future as banks compete with one another provide seamless services using the latest financial
technologies available to them 21 , could also inadvertently facilitate the ease of laundering
corrupt proceeds across borders.
At the same time, with the population becoming better educated, we are anticipating
higher expectations and demands of faster turn-around times for the completion of corruption
investigations. Law enforcement agencies including CPIB will need to find ways to expedite
our investigation processes without compromising on the quality of the investigations, throughleveraging on new technologies and tools, as well as amending relevant legislations on
corruption to make sure they stay relevant.
While the institutional and practical developments above have resulted in a lower
incidence of corruption in Singapore over the past decade, the CPIB cannot rest on its laurels
and is constantly on the lookout for new developments and game-changers that will affect its
ability to carry out its mandate effectively. The CPIB will continue to adopt a multi-stakeholder
approach in preventing, investigating and reducing corruption both domestically and globally.

Refer to: https://www.cpib.gov.sg/case-studies/public-sector/corruption-and-abetting-gst-tourist-refund-fraud
FAST (Fast And Secure Transfers) was launched in March 2014 - an electronic funds transfer service thatenables customers of 19 participating banks to transfer Singapore Dollar funds from one bank to another almost
instantly. The customer enters the recipient’s bank account number and the amount, and the funds are credited.
21
Regulatory Sandbox for Innovative Fintech Experimentation. Refer to:https://www.smartnation.sg/initiatives/Services/regulatory-sandbox-for-innovative-fintech-experimentation
19
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