Singapore – MAS Fines for Substantial Shareholding Disclosure

Singapore – MAS Fines for Substantial Shareholding Disclosure

On 17 January 2020, SIN MAS issued fine for failure to disclose shareholdings.

  • Imposed $200,000 civil penalty on Mr Lim Soon Fang for not disclosing changes in, and providing false information re. shareholding in Asia-Pacific Strategic Investments.
  • This is the first civil penalty action by MAS for breaches of shareholding disclosure requirements since the civil penalty regime was extended to this in November 2012.


  • Mr Lim became a substantial shareholder of ASIL in October 2013, and between October 2013 and October 2014, Mr Lim traded in ASIL shares, resulting in changes in his interests.
  • His trades had on multiple occasions also led to him ceasing to be or becoming a substantial shareholder of ASIL, which are events that must be disclosed.


  • During this period, Mr Lim contravened section 135 of the SFA for failing to notify ASIL that he had become a substantial shareholder of the company on four occasions.
  • Section 136(1) of SFA for failing to notify ASIL of changes in interests on 32 occasions.
  • Section 137 for failing to notify ASIL he ceased to be substantial shareholder 5 times.
  • Mr Lim also provided false information to ASIL regarding his transaction volume in ASIL shares and his shareholding in the company on three occasions.
  • Mr Lim admitted that he had been reckless in breaching his disclosure obligations under the SFA and in furnishing false information regarding his shareholding in ASIL.