For a full explanation of the money mule offences and the elements required to prove them, see our pages on the money mule offences and their punishment and the elements and defences.
How do the courts decide the sentence?
The money mule offences are found in the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 (“CDSA”) and the Computer Misuse Act 1993 (“CMA”).
The Sentencing Advisory Panel’s Guidelines for Scams-Related Offences, published in August 2024, treat imprisonment as the norm for these offences. The guidelines are not binding, and the High Court has departed from them in some respects.
The CDSA grades the offences by state of mind
The High Court has described the offences in Part 6 of the CDSA as a spectrum of culpability, which the sentence reflects:
- at the top, the person who knows or has reasonable grounds to believe that the arrangement involves criminal proceeds (section 51(1));
- below that, the person who acts rashly or negligently (section 51(1A)); and
- at the bottom (arguably), the person who merely fails to take reasonable steps (section 55A).
Handing over a payment account (section 55A(1)(b)(ii) of the CDSA): the Erzan benchmark
The benchmark is six months’ imprisonment for a first offender convicted after trial, in the typical case where an existing account is handed over, the account is then used to move criminal proceeds, and the offender was motivated by gain. Departing from the Sentencing Advisory Panel’s guidelines, the court held in Mohamed Erzan Taib Zohri v Public Prosecutor and other appeals [2026] SGHC 183 (“Erzan”) that being motivated by gain is almost invariably part of the typical case and is not an aggravating factor, since in almost all cases the offender was offered something.
A distinction is drawn between being offered a payment and actually receiving it. Where the offender actually received and kept the payment, two things follow:
- the court may take the actual benefit into account in fixing the sentence; and
- the court may impose a fine equal to the sum received (a “disgorgement fine”), in addition to imprisonment, so that the offender keeps no benefit from the offence.
Factors that increase the sentence include:
- opening a new account in order to hand it over;
- handing over more than one account;
- abuse of a position of trust (for example, a director handing over a company account);
- continuing after being told that the account had been misused;
- significant sums passing through the account; and
- the involvement of vulnerable victims, the elderly being presumed to be vulnerable.
The weight given to the sum and to vulnerable victims depends on how far these were foreseeable to the offender. An adult is normally taken to know that scammers are likely to target the elderly, but a young offender may not fully appreciate this.
Factors personal to the offender fall on both sides:
- aggravating: other charges taken into consideration, and previous convictions; and
- mitigating: remorse, restitution, co-operation with the authorities, and a plea of guilty. The absence of previous convictions is neutral, not mitigating.
As an example, one of the offenders in Erzan had suspected that her accounts would be used for illegal activity but ignored her suspicion. She handed over her existing bank account and allowed a cryptocurrency account to be opened using her Singpass. More than $600,000 passed through the bank account, and she received and spent the $500 she had been promised. When sentencing, the court started from the benchmark of six months and increased it by five months (to 11 months) for these factors. It then applied a reduction of 30% for her early plea of guilty. Her sentence of seven months and two weeks’ imprisonment, with a fine of $500 to take back the payment, was upheld.
Moving money through one’s own account (section 55A(1)(b)(iii) of the CDSA): the Galvez matrix
For this form of the offence, instead of following the Erzan benchmark, the court uses a harm-culpability matrix similar to the kind used for money laundering offences (see our page on how the courts sentence money laundering offences). The court assesses the harm caused (slight, moderate or severe) and the offender’s culpability, meaning blameworthiness (low, medium or high), identifies the range for that combination, chooses a starting point within it, and then adjusts for factors personal to the offender.
The factors considered include the amount moved; the vulnerability of the victims and whether the offender knew of it; and the duration of the offending and the number and frequency of the transactions. The ranges, for an offender who claims trial, are:
| Culpability \ Harm | Slight | Moderate | Severe |
|---|---|---|---|
| Low | Fine up to $50,000 and/or up to 6 months | 6–12 months | 12–18 months |
| Medium | 6–12 months | 12–18 months | 18–24 months |
| High | 12–18 months | 18–24 months | 24–36 months |
Galvez Mary Joe Blanco v Public Prosecutor [2026] 3 SLR 1427 (“Galvez”) was decided on 21 May 2026 by the High Court. The offender was a foreign domestic worker who had been drawn in by an older co-worker. She did not hand over her account. Over about two weeks, she received $118,133.00 into it on the instructions of a third party and transferred most of it to an account in Thailand, receiving $1,151.50 for doing so. Some of the money was traced to two scam victims, one of them 70 years old.
The court assessed harm as moderate and culpability as low, because she had been misled by her co-worker and the illegality became obvious only in the last six of the 15 days covered by the charge. That gave a range of 6 to 12 months, and the court took a starting point of seven months to reflect the elderly victim. It reduced this by one month because she had given up her gain and co-operated, and then by 30% for her early guilty plea, arriving at slightly more than four months. As this was more than the 40 days’ imprisonment imposed by the District Court, and the Prosecution had not sought an increase, her appeal was dismissed and the 40-day sentence was left in place.
Singpass offences (sections 8A and 8B of the CMA)
The Sentencing Advisory Panel’s guidelines, as noted by the High Court in Erzan, give a starting sentence of 6 months’ imprisonment after trial for disclosing one’s own Singpass credentials under section 8A of the CMA, and double that (i.e., 12 months) for an offence under section 8B (which covers obtaining, retaining or supplying another person’s credentials), reflecting the greater culpability of a person who discloses someone else’s credentials.
Conduct before 8 February 2024: the predecessor offences
Conduct before 8 February 2024 continues to be charged under the predecessor provisions, and the sentences for those offences are lower (see the table below). For a person whose conduct straddles 8 February 2024, or who is charged with offences on both sides of that date, which provisions apply to which conduct is a matter of real importance to the sentence.
What is the sentencing range at a glance?
The table below summarises the sentencing guidance for each offence and the sentences seen in the cases reviewed. Every case turns on its own facts, and the figures are a guide only. Offences marked * apply to conduct before 8 February 2024.
| Offence | Sentencing guidance | Sentences seen in decided cases |
|---|---|---|
| Handing over a payment account CDSA s 55A(1)(b)(ii) | Benchmark of 6 months after trial for one existing account handed over (Erzan), adjusted for the factors described above | About 6 to 12 months, usually with a fine equal to the payment received |
| Moving money through one’s own account CDSA s 55A(1)(b)(iii) | Harm-culpability matrix running from a fine to 36 months (Galvez) | 40 days in Galvez, left in place on appeal, but the High Court indicated that slightly more than 4 months would have been appropriate |
| Disclosing one’s own Singpass credentials CMA s 8A | Starting point of 6 months after trial (Sentencing Advisory Panel guidelines, as noted in Erzan); caning possible for offences from 30 Dec 2025 | 7 months and 2 weeks after an early plea of guilty (Public Prosecutor v Haryani binte Juraimi [2026] SGDC 163) |
| Obtaining, retaining or supplying another person’s Singpass credentials CMA s 8B | Starting point of 12 months after trial (Sentencing Advisory Panel guidelines, as noted in Erzan); caning possible for offences from 30 Dec 2025 | No reported judgment to date |
| Handing over an account; opening an account to hand it over; disclosing Singpass credentials* CMA s 3(1); Penal Code 1871 s 417; CMA s 8(1) | Benchmarks of 3 to 4 months after trial for handing over or opening an account (higher where both are charged), and 4 months for disclosing Singpass credentials (Erzan) | 4 months and 14 weeks after pleas of guilty, in two cases where a new account had been opened to hand over (Public Prosecutor v Nooryati binte Mion [2026] SGDC 320; Erzan); young offenders have received probation |
| Moving money through one’s own account* Payment Services Act 2019 s 5 | Starting point of 3 weeks for the typical unlicensed transfer (Vijay Kumar v Public Prosecutor [2023] 5 SLR 983); must not be calibrated against s 55A | 15 weeks on appeal, where about $159,700 was moved and the offender carried on after an account was frozen (Nur Diyanah bte Mohamed Ramdan v Public Prosecutor [2026] SGHC 174) |
| Money laundering (knowing or having reasonable grounds to believe) CDSA s 51(1) | Harm-culpability matrix in Huang Ying-Chun v Public Prosecutor [2019] 3 SLR 606; caning possible in specified cases involving scam proceeds, for offences from 30 Dec 2025 | 7 months and 1 stroke of the cane for a cash collector (reported by the police, 2026); 20 months for a cash collector who collected $124,060 from five victims (Public Prosecutor v Chan King Vun [2026] SGDC 208) |
Can the sentence be a fine?
Fines arise in two ways:
- Fines to take back the payment received: In the cases reviewed, such fines ranged from $50 to $4,100; the largest was imposed in a 2026 case concerning a company’s account (Public Prosecutor v Lee Yun Han [2026] SGDC 204), and included payments received for other accounts whose charges were taken into consideration. Where the promised payment was never received, no such fine is imposed.
- A fine as the only punishment: The Galvez matrix allows a fine in its lowest band (slight harm and low culpability). In Galvez, however, the court rejected the submission that people who were themselves deceived into the role (sometimes called “victim mules”) should start from a fine, holding that most cases have features of both “money mules” and “victim mules” and that the CDSA already grades culpability according to the offender’s state of mind.
In the decisions reviewed, no sentence of a fine alone was imposed for an offence under section 55A of the CDSA. Whether a fine alone may be appropriate in a particular case depends on its facts.