CURRENT ISSUES FACED BY SINGAPORE IN INVESTIGATING,PROSECUTING & ADJUDICATING CORRUPTION CASES
Wee Keng Lock Raymond *1.

Singapore is well known in the region for her efficient government, tough laws and zerotolerance towards corruption. It is well-established that the four pillars supporting her fightagainst corruption are, namely: “Effective Laws”, “Independent Judiciary”, “Effective
Enforcement”, “Responsive Public Service”. Together with strong “Political Will” and zerotolerance towards corruption, these four pillars have provided Singapore with the guiding
principles to grow from a “Third World Nation” to a modern, technology-savvy, globalizedcity state with a “First World” economy within a short span of 50 years.

ZERO TOLERANCERESPONSIVEPUBLIC SERVICEEFFECTIVE
ENFORCEMENTINDEPENDENTJUDICIARY

EFFECTIVELAWS

POLITICAL WILL*

Assistant Director Overseeing Training for the Investigation Department, Corrupt Practices Investigation Bureau,
Singapore.

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I.

EFFECTIVE ENFORCEMENT

2. The Corrupt Practices Investigation Bureau (CPIB) is the sole agency tasked with theenforcement of anti-corruption laws in Singapore. The CPIB was established in 1952 when thecolonial government then realized that the Police Anti-Corruption Branch (ACB) was ineffective
and rife with corruption. The need for an effective anti-corruption agency and strong
enforcement action was crucial in the fight against corruption in post-war Singapore. The CPIB
was set up as an independent agency, which reports to the Prime Minister’s Office to keep
corruption in check.
3. The CPIB’s efforts in enforcing the corruption laws are well documented through the annalsof Singapore’s history, especially in the early years of nation building after Singapore obtained
independence from the British. Today, CPIB continues to stay vigilant, remain important andrelevant in keeping Singapore “Clean”.
4. In terms of strategy, the CPIB adopted a 3-D approach in enforcing corruption; mainly, to“Detect”, “Deal” and “Deter”. The CPIB consciously embarked on the following initiatives toensure that the 3-D approach is adhered to:a. Continuously building public confidence in the country by promoting CPIB’s
commitment in fighting corruption, so as to increase public awareness andwillingness to report corruption crimes.
b. Zero-tolerance for corruption by investigating all cases irrespective of how small thesum of money involved and by pursuing anonymous complaints.
c. Encouraging whistle-blowing and self-policing within government departments.
d. Embarking on the enforcement of targeted corruption-prone arease. Cooperation with other enforcement and regulatory agencies to weed out potential
corruption trends.
f. Embarking on pro-active intelligence projects.
g. Consciously engaging in international fora and cooperation on anti-corruption
initiatives.
5. However, in a globalized world today, the key challenge for any enforcement agency is tohave the ability to stay nimble, responsive to the changing environment and challenges while
also staying relevant to operate across national borders combating transnational crimes. As weknow, transnational crime is borderless. Organized crime, criminal activities and its players
operate outside national borders or across borders and their adverse consequences have noboundaries. With globalization, criminal elements are able to move and operate more freely and- 118 -

together with technology; the perpetrators are able to transfer the proceeds of crime
instantaneously.
6. Sovereign nations, with their respective borders and laws, are handicapped, constantly
facing challenges and barriers to arrest, prosecute and deter criminals who operate outside theboundaries of the offended state. In order to commence investigations against such transnational
criminals, the offended country or policing agency are often faced with limitations of its existinglaws, extraterritorial rights and jurisdiction of dealing with either her citizens or non-citizens.
7. Like any other country, transnational crimes do affect Singapore. Corruption is a known
transnational crime that knows no borders. As such, the CPIB is also constantly faced withcorrupt criminal activities with international implications whether involving her citizens or noncitizens.
II. SINGAPORE AND THE CPIB’S EXPERIENCE
8. In recent years the CPIB has faced many challenges and some of the current issues faced bySingapore in investigating, prosecuting and adjudicating corruption cases take the following
forms:a)Transnational investigation,b)

Increase in formal foreign requests for assistance (MLAT) lacking inunderstanding of the local legal framework,c)

Impact of social media,d)Money laundering investigation, following the money trail,e)Effective laws,f)

Forensic evidence,g)International cooperation; andh)Greater transparency.

Note: The CPIB will share a case study from Singapore which encompasses the above eight
issues.
III. BACKGROUND OF THE CASE
9. In 1994, the CPIB investigated one Wilson Raj Perumal (WRP), a Singapore national, forattempting to offer a bribe of S$3,000/- to a soccer player in a local non-professional league
competition to fix the results of the game. WRP was found guilty and convicted in court and- 119 -

sentenced to 12 months, imprisonment. In 1997, the CPIB investigated a local syndicate forbribing players and officials to fix soccer matches in Singapore’s national semi-professionalsoccer league. WRP and 12 others (8 soccer players, 1 referee, 1 financier and 2 runners) were
investigated by CPIB for “Match Fixing”. WRP was subsequently charged (total of 12 counts)
and convicted in court in 1998 for the offence of bribing a soccer referee and players in return for
fixing the results of matches. WRP was sentenced to imprisonment for 16 months.
10. In organized sports, “Match Fixing” occurs when a scheduled match is played out to a predetermined result, which violates the spirit of the game, short-changing the paying fans, andwould more often than not involve an organized syndicate which is deeply entrenched into
criminal activities such as corruption, illegal bookmaking and cheating the Tote-Board. The
Singaporean authorities recognized that “Fixed Matches” or “Thrown Games” are motivated bygambling and corruption. If left unchecked, there will be a rise in criminal elements, which inturn would fuel social ills and cause disrepute to the sport.
11. In combating illegal soccer betting and corruption in the soccer fraternity, the Singapore
Tote-Board decided to accept soccer bets for matches played in Singapore and popular soccer
leagues in Europe. The CPIB worked closely with the soccer fraternity to weed out these corrupt
players and officials by conducting regular polygraph examinations and through the investigationof suspected individuals. For the last decade, the CPIB had clamped down hard on match-fixers
by diligently investigating every allegation of soccer “Match Fixing”, so much so that WRP and
his corrupt associates had to leave Singapore and operate overseas.
IV. THE CASE STUDY
A. Transnational Investigation
12. Instead of mending his ways, WRP, who is a hard-core criminal, continued his soccer“Match Fixing” exploits. In early 2011, WRP was arrested in Finland for using forged travelling
documents and was also wanted by Interpol for being involved in “Match Fixing” of soccer
matches throughout several European soccer leagues such as the UK, Finland, Hungary, Italy,
Croatia, and Bulgaria. (Note: At this juncture, WRP was also a fugitive, on the run from theSingaporean authorities for committing a spate of crimes). While in Finnish custody, WRP ratted
on his associates and identified his boss and financier to be one Dan Tan, another Singaporean,as the mastermind behind the “Match Fixing” scandal. Dan Tan was alleged to head one of theworld’s largest and most aggressive “Match Fixing” syndicates, supposedly linked to the triads
from China and the Balkan states (e.g., Croatia, Serbia, etc.) and ties with the Russian and Italianmafias. WRP was sentenced to two years, imprisonment and spent a year in the Finnish prison
before being handed over to the Hungarian authorities in 2012 to help them with theirinvestigation on “Match-Fixing”. On the other hand, Dan Tan, who was implicated by WRP,
was indicted by the Italian and Hungarian authorities in 2011 and 2012, respectively, in absentia.

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B. Increase in Foreign Requests for Assistance Lacking in Understanding of the Local
Legal Framework
13. Like many countries, Singapore does not have extradition treaties with most of the European
states. The Singapore authorities had no jurisdiction over the “Match Fixing” cases that took
place in the European leagues. Like many transnational crimes, criminal activities and organizedcrime groups that operate outside Singapore’s national borders render the local (Singapore)
authorities helpless as they have no locus standi over the investigation.
14. In investigating one of the biggest “Match Fixing” scandals in Europe, the European
authorities had sought the assistance and involvement of the Singapore authorities. However,
due to the differences in legal framework, Singapore was unable to partake in the above
investigation from the onset.
C. Impact of Social Media
15. In early 2013, “Match Fixing” news became the flavour of the month. At every available
opportunity, the social media would highlight that members of one of the main syndicates
involved in the scandals were Singaporeans. This led to the inference that Singapore was aninternational hub for soccer “Match Fixing” and where organized crime in the soccer fraternity
was allowed to thrive freely. The social media had carved an agenda to make Singapore takecentre stage in the above scandals. The European authorities, without verifying the legitimacy ofsome of the information, fueled the slanted agenda by giving the media access to interview WRP(who was under house arrest) to sensationalize the “Match Fixing” scandals. Dan Tan, who was
located in Singapore, was also not spared. The media, both foreign and local, had also
approached Dan Tan for his comments, and his versions on the alleged “Match Fixing” scandal
were further fanned to create more heat.
16. While under house arrest in Hungary, WRP was happily “singing” away and giving
interviews to the media on the role he played and how the Singaporean syndicate fixed matches
all over Europe, Africa, the Middle East and Asia. WRP felt that his arrest in Finland was abetrayal by the syndicate. Thus, WRP decided to get even by ratting on Dan Tan. WRP
implicated Dan Tan as a financier and exposing Dan Tan’s links with criminal elements in the
Balkans, Russia, Italy and China. WRP’s agenda was to put himself and Singapore in the
spotlight in return for being a “star witness” to help the European authorities with theirinvestigation. Dan Tan, whose name was linked to several sports-related companies, confirmed
his involvement in some soccer-related business venture in Europe in organizing friendly
matches, but he denied his involvement with WRP in fixing matches. Dan Tan counter-allegedthat WRP was not trustworthy, a traitor; and had run off with his money to set up a soccerrelated business to rival him and his associates.
17. Within a month, WRP and Dan Tan achieved infamous cult statuses. Like celebrities, themedia openly aired their feud. Exposure of their scandalous mud-slinging tirades at each othergrabbed tabloid headlines across the globe. Meanwhile, unflustered by the fanfare andaccusation of being indifferent, the Singapore authorities, from the ringside, were gathering- 121 -

momentum to throw a knock-out punch to floor the foreign media for their biased reporting andto bring the house down by knocking out the corrupt “Match Fixing” syndicate.
D. Money-Laundering Investigation: Following the Money Trail
18. As early as 2012, upon receiving news of the allegations that a transnational organized crime
syndicate based in Singapore was actively involved in international “Match Fixing”, theSingapore authorities, in their typical low profile fashion, had established a soccer Joint
Investigation Team (JIT) led by senior investigators from the Singapore Police Force (SPF), theCPIB and the Intelligence Department to look into the matter. The lack of visible response to themedia, both local and foreign, about Singaporeans’ involvement in international “Match Fixing”
was a deliberate tactic by the Singapore authorities to put the syndicate off their guard.
19. In March and May 2013, senior members of JIT Singapore met up with representatives of
the Global Anti-Match-Fixing Task Force, Interpol and Europol in Lyon, France to review
evidence and obtain information on Singaporeans’ involvement in “Match Fixing”.
E. Effective Laws
20. With the information provided by WRP (via the numerous tabloid interviews) and theEuropean authorities, the JIT invoked the powers provided for in the Prevention of Corruption
Act (PCA), Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits)
Act (CDSA) and the Criminal Law (Temporary Provision) Act (CLTP) to deal with the corrupt
practices and the organized crime syndicate.
21. Singapore’s well-defined laws state the following:a) Liability of citizens of Singapore for offences committed outside Singapore.
Section 37(1) of the Prevention of Corruption Act, Chapter 241 (PCA) provides that “inrelation to any citizens of Singapore, outside as well as within Singapore; and where an
offence under this Act is committed by a citizen of Singapore in any place outside
Singapore, he may be dealt with in respect of that offence as if it had been committed
within Singapore”.
b) Concealing or transferring benefits of criminal conduct.
Section 47(1) of the Corruption, Drug Trafficking and Other Serious Crimes(Confiscation of Benefits), Chapter 65A (CDSA) provides that “Any person who (a)conceals or disguises any property which is, or in whole or in part, directly or indirectly,
represents, his benefits from criminal conduct; or (b) converts or transfers that property or
removes that property or removes it from the jurisdiction, shall be guilty of an offence”.
c) Power of Minister to make orders
Section 30 of the Criminal Law (Temporary Provisions) Act, Chapter 67 (CLTP)
provides that “Whenever the Minister is satisfied with respect to any person, whether the
person is at large or in custody, that the person has been associated with activities of acriminal nature, the Minister may, with the consent of the Public Prosecutor – (a) if he issatisfied that it is necessary that the person be detained in the interests of public safety,- 122 -

peace and good order, by order under his hand direct that the person be detained for any
period not exceeding 12 months from the date of the order; or (b) if he is satisfied that itis necessary that the person be subjected to the supervision of the police, by order directthat person be subject to the supervision of the police for any period not exceeding 3
years from the date of the order”.
22. As such a large dragnet was cast, intelligence monitoring and gathering were carried out.
The Ministry of Home Affairs (Political Will) directed the authorities to use whatever resources
available to weed out the individuals involved in the international “Match-Fixing” scandal,
which had cast Singapore in a bad light.
23. Tenaciously, investigators worked long hours to gather evidence against the perpetrators.
Every company, business and financial document linked to the syndicate members was inspected,
and all bank transactions and money trails were thoroughly scrutinized. Nothing was left tochance, and no stones were left unturned to nail the notorious match-fixers.
F. Forensic Evidence
24. While monitoring Dan Tan and his syndicate members, the investigators had a breakthrough in early 2013. The CPIB had received reliable information that one Eric Ding Si Yang,a known associate of Dan Tan, had contacted three Lebanese soccer match officials (a referee
and two linesman) to help the syndicate fix the Asian Federation Confederation (AFC) Cup
match between Singapore’s Tampines Rovers FC and India’s East Bengal FC to be played in
Singapore on 3 April 2013.
25. Investigations revealed that Eric had arranged for three local prostitutes to provide sexual
gratification to the three Lebanese match officials prior to the above-referenced match to inducethem to fix the result. Eric’s contact point with the three match officials was the referee, named
Ali. The CPIB mounted a sting operation and arrested the three prostitutes and match officials at
the premises of the hotel when they were caught with their pants down. The three Lebanesematch officials were subsequently charged for corruption in April 2013. They pleaded guilty incourt for corruptly receiving sexual gratification in return for fixing the result of a soccer match,and the three match officials were each sentenced to three months’ imprisonment.
26. Eric was subsequently charged a month later for corruption. He had requested a trial for hisrole in bribing the three Lebanese match officials. In the course of investigating Eric and thethree Lebanese match officials, the CPIB seized numerous lap-top computers, storage devices,and hardware. The syndicate had engaged computer vendors to use encrypted software toprotect passwords, files, e-mails and data stored in the computer devices. After much effort, theforensic lab officers managed to crack the encrypted devices, which revealed Eric’s involvement
in soccer “Match Fixing”. Forensic examination also assisted the authorities to recover trails of
e-mail correspondence between Eric and Ali, the Lebanese referee, dating back to 2012.
27. In Eric’s corruption trial, Ali testified against him, and with corroboration of forensic
evidence found in Eric’s computer devices, the court found Eric guilty as charged and convicted
him of corruption (3 counts). Eric was subsequently sentenced to three years’ imprisonment for- 123 -

corruptly bribing three Lebanese soccer match officials in the form of sexual gratification withprostitutes in return for fixing the result of a soccer match.
28. Further probe by the CPIB suggested that Dan Tan may have been involved in the
procurement of the three local prostitutes through a middle-man for Eric.
29. After Eric and the three Lebanese match officials were arrested in April 2013, the Singapore
authorities led by the specially formed JIT members carried out a major operation in September
2013. Dan Tan and a dozen other individuals linked to the “Match Fixing” syndicate werearrested and investigated for their involvement in organized criminal activities. The eventual
crackdown on a Singapore-based international “Match Fixing” syndicate led to the incarcerationof five members of the syndicate, including Dan Tan, under the CLTP Act. The authorities
continue to investigate Dan Tan, Eric and the syndicate members for offences under the CDSA,
with the view to convict them for engaging in money laundering activities and to seize theirmonies and assets as proceeds of crime. As for WRP, the Singapore authorities are patiently
waiting for the European authorities to repatriate him back so that he can face criminal charges
and be tried in Singapore’s courts.
G. International Cooperation
30. In investigating the above series of cases, the Singapore authorities, including the CPIB, did
not shun away from international cooperation or investigating transnational crime. In fact weembrace international cooperation, and the CPIB regularly participates in international anticorruption initiatives and forums. The CPIB also works closely with its counterparts such as the
Malaysian Anti-Corruption Commission (MACC), Brunei’s Anti-Corruption Bureau (ACB),
Hong Kong’s Independent Commission Against Corruption (ICAC) and has also signed a
Memorandum of Understanding (MOU), known as the Southeast Asian Parties Against
Corruption (SEAPAC), to cooperate on anti-corruption initiatives.
31. Continuing on the topic of “Match Fixing”, and with the recent blitz by the CPIB on
allegations of “Match Fixing”, the Bureau had also investigated another local syndicate in mid2012 when the CPIB received information that a Singapore national, one Selva, had conspiredwith a Malaysian, one Thana Segar, to bribe a soccer referee from the Football Association of
Malaysia to fix the result of a match between the Sarawak FA of Malaysia and the Lions XII of
Singapore. The match was to be played in Singapore, and when the perpetrators set out inmotion to carry out their corrupt act, the CPIB arrested Selva, Thana Segar and the referee andcharged them in court for corruption.
32. Thana Segar who was released on bail pending his court trial subsequently absconded andjumped bail. With the assistance and cooperation of our Malaysian counterparts from the MACC,
Thana Segar was located in Malaysia. In August 2014, Thana Segar was apprehended by officers
from the MACC and surrendered to the CPIB’s custody to face corruption charges in
Singapore’s courts. The successful arrest of Thana Segar is a result of the close ties that
Singapore has with her neighbours in fighting corruption and recognizing the binding ties via
MLATs.

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H. Greater Transparency
33. As mentioned earlier in this paper, the CPIB must continue to stay vigilant, remain
important and relevant in its ability to stay nimble and responsive to the changing environmentand challenges. The Singapore authorities are having to face a higher legal threshold recently
when investigating criminal cases and prosecuting individuals in court and are currently
reviewing the processes and procedures of the Criminal Justice System (CJS). One of thechanges and enhancements in the criminal procedure code is the introduction of evidence by boththe prosecution and defence in the discovery process during pre-trial conferences for Penal Codeoffences.
34. The introduction of the discovery process is to ensure that the accused person is notwrongfully prosecuted and has a fair trial. Any discrepancies and alibis brought up by bothprosecution and defence during the discovery process shall be promptly verified or further
investigated before going for trial or before the defendant enters into a plea agreement. The
discovery process, which entails greater transparency, will help improve judicial fact-finding andthus would not waste the court’s time to mete out justice swiftly.
35. With the discovery regime (which is yet to affect corruption cases) in place, it would
definitely accord more scrutiny by the defence counsel on our methods of investigation in the
future. This in turn would also give the media and members of public more access to informationon our work processes and modus operandi when cases go for trial in the courts.
36. In order to cope with greater transparency and scrutiny of our tradecraft, the CPIB must
continuously maintain a high standard of professionalism in its investigation processes andmethods. Besides investing in continuous training of its officers, new technology and resources,
the CPIB had also put in place sound audit procedures as part of good governance on its work
processes so as to ensure that the standard of investigation and its officers remain consistently
high in delivering results and providing quality public service.
37. In conclusion, I would like to take this opportunity to thank the organizers for allowing me
to share in this paper, Singapore and CPIB’s experience of trends and challenges that I am sureother jurisdictions are currently facing when investigating, prosecuting and adjudicating
corruption cases.

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