Stock image of villas in Southeast Asia, for illustration purposes. Property can act as a mechanism through which illicit funds may be moved, layered and given an appearance of legitimacy. (Photo: Unsplash)
Southeast Asia has emerged as a significant hub for organised cyber-scam activity, generating illicit proceeds that are often subsequently cleaned, stored and integrated into the financial system.
Increasingly, there are indications that property is among the vehicles of choice, potentially serving not only as a base of operations but also as a means of giving illicit proceeds a more legitimate appearance.
For cities such as Singapore, a major centre for regional financial and real estate flows, the question of whether illicit funds from scam-linked networks could find their way into the local market is one that regulators are taking seriously.
The operators of Southeast Asia’s cyber-scam networks have, in some cases, built operations that resemble real estate businesses as much as criminal ones.
Scam compounds can range from sprawling rural complexes with sleeping quarters, shops and facilities, to a single floor of a legitimate office building or a rented house in an urban area.
Last year, police in Malaysia busted a cryptocurrency scam ring operating fraudulent call centres in high-end condominiums in Johor Bahru.
Closed casinos and apartment blocks in Southeast Asian cities were also repurposed to house scam operations during the Covid-19 pandemic, The Conversation reported.
The choice of property type may reflect a deliberate calculation. Each format can offer a different degree of visibility and operational cover, depending on the jurisdiction and the scale of activity involved.
The link between property and criminal proceeds can run in both directions.
Property can serve as the infrastructure from which scams are run, and as a vehicle through which profits are subsequently cleaned.
In some reported cases, laundered funds have been traced through casinos and real estate firms linked to politically exposed persons.
Layering ownership across real estate vehicles is a documented technique for fragmenting audit trails and placing illicit proceeds behind a veneer of legitimate commercial activity.
Understanding the scale of what drives these flows provides useful context.
Scam victims in Singapore lost S$913 million in 2025, with over 37,000 cases reported. Many of these losses have been attributed to scam centres operating out of Cambodia, Laos and Myanmar, which target victims in wealthier economies such as Singapore and Hong Kong.
Such operations are reported to have gravitated towards jurisdictions where regulatory gaps and weaker enforcement may create more permissive operating conditions, deploying data infrastructure to support activities such as romance scams and fraudulent investment platforms.
There are indications that these networks are evolving into more sophisticated actors, incorporating tools such as deepfakes and crypto-based layering services.
Once proceeds are generated, they may move through shell companies, overseas accounts and property investments before re-entering the financial system — at which point the trail may become more difficult to follow using conventional means.
Across the region, the financial sector's traditional response — list-based screening and static customer due diligence — is generally not designed with this threat profile in mind.
Networks engaged in scam-linked laundering typically structure ownership to avoid matching known watchlists, with beneficial ownership dispersed across multiple jurisdictions.
A property transaction may involve a locally incorporated entity whose ultimate controller sits several layers removed in a jurisdiction that may have more limited transparency requirements.
Singapore's Anti-Money Laundering and Other Matters (Estate Agents and Developers) Act 2025, which came into operation in July 2025, represents a further strengthening of a framework that has been in place since 2010 and enhances requirements in the real estate sector.
Notably, it extended due diligence obligations to cover not only real estate agents’ own clients, but also unrepresented counterparties to property transactions, reflecting the view that the layered nature of modern laundering may require a broader scope of scrutiny.
The Council for Estate Agencies in Singapore has reiterated that obligations include verifying client identity, screening against regulatory lists and reporting suspicious transactions to the authorities, with due diligence records maintained for at least five years.
Stock image of condos, for illustration purposes. For asset owners and developers, particularly those with cross-border exposure, the considerations are broader. (Photo: Unsplash)
For property agents and brokers, risk tends to be most acute at the point of transaction.
Source-of-funds verification that goes beyond accepting documentation at face value is increasingly regarded as good practice.
This includes considering whether the buyer’s financial profile is consistent with the purchase, whether the entity structure is proportionate to the deal, and whether third-party involvement is adequately explained.
Routine adverse media checks on buyers, their associates and linked entities are similarly becoming more commonly expected in some risk-sensitive contexts, as is attention to property management companies or nominee arrangements that may obscure true beneficial ownership.
For asset owners and developers — particularly those with cross-border exposure — the considerations are broader.
Ownership transparency measures, including registers of beneficial owners and periodic reviews of tenant or buyer profiles, are increasingly emphasised by regulators and institutional counterparties.
Where properties are leased to businesses in higher-risk sectors, enhanced due diligence on the lessee’s ultimate ownership and funding sources is increasingly considered a common prudent practice.
Thai police raided a luxury housing project in Greater Bangkok. Most units in the project are said to have been purchased through a nominee with suspected links to a crime syndicate under investigation. (Photo: The Irrawaddy, Bangkok Post)
Real estate lawyers often occupy a critical position in the due diligence chain.
Conveyancing due diligence is generally understood to include verification of the source of purchase funds.
Where transactions present unusual structures, opaque ownership or inconsistent sourcing of funds, suspicious transaction reporting obligations may arise.
Nominee and power-of-attorney arrangements that appear designed to distance the ultimate principal from a transaction are among the patterns that regulators have identified as meriting closer scrutiny.
For banks and financial institutions, the challenge is one of visibility.
Scam-linked networks tend to be structured in ways that can evade conventional screening — for example, beneficial ownership may be dispersed, entity names rotate over time, and transactions may be sized or routed in ways that reduce the likelihood of triggering standard thresholds.
Network analysis maps relationships between entities, accounts and individuals rather than screening each in isolation. It is increasingly identified as one approach that can help highlight clusters of activity that may merit closer review, with particular attention to layered or opaque corporate structures where looking through to the ultimate beneficial owner becomes important.
There is also a growing conversation around event-driven or perpetual KYC (Know Your Customer) processes. For instance, a customer profile that appeared low-risk at onboarding may look materially different following a sanctions designation, an adverse media event or a change in ownership structure.
Southeast Asia's scam centres are often described as representing a convergence of organised crime activity and financial engineering at a considerable scale.
Property can act as a key mechanism through which illicit funds may be moved, layered and given an appearance of legitimacy.
Against this backdrop, Singapore has taken deliberate steps to strengthen its real estate anti-money laundering framework, and the regulatory direction is clear.
A key challenge for professionals is to match the evolving nature of the risk with controls that go beyond static documentation. These may include approaches built on network analysis, ownership transparency and a more continuous, risk-sensitive view of the counterparties they transact with.
Property will likely represent an attractive destination for illicit funds, particularly where due diligence frameworks leave gaps unexamined.
Closing those gaps should be seen as a shared task involving regulators, institutions and property professionals alike.
Chua Choon Hong is senior director and head of the financial crime practice group for Asia Pacific and Middle East at Moody's.