1 This is a case involving scams-related offences of relinquishing and handing over control of bank accounts, as well as the unlawful parting of possession with one’s national identity card.

2 Through her friend, Mohd Rafiez Bin Mohd Ali (“Mr Rafiez”), the accused, Nooryati Binte Mion (“Ms Nooryati”), a 51-year-old Singaporean, opened and relinquished or handed over control of two new bank accounts, which were subsequently used by unknown syndicate members to launder funds, for financial gain. She also handed over an existing bank account for the same purpose. She received a total of S$50 in exchange for the three accounts. She also unlawfully handed over her national identity card to Mr Rafiez.

3 Ms Nooryati has pleaded guilty to three charges, namely:

(a) a charge of unlawfully parting with possession of her identity card to Mr Rafiez under section 16(2)(a) of the National Registration Act 1965 (2020 Rev Ed) (“NRA”);

(b) a charge of abetting by aiding the offence of unauthorised access to computer material under section 3(1) (read with section 12(1)) of the Computer Misuse Act 1993 (2020 Rev Ed) (“CMA”) by granting Mr Rafiez access to a new bank account she opened by passing the bank card for that account and relinquishing the account to him; and

(c) a charge of entering into an arrangement by handing over control of her existing bank account to unknown persons without taking reasonable steps to ascertain their purpose of accessing her account under section 55A(1)(a)(i) read with section 55A(1)(b)(ii) of the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 (2020 Rev Ed) (“CDSA”).

4 She has also consented for five other charges to be taken into consideration for the purpose of sentence (“TIC”), namely:

(a) a mirror charge of cheating a bank under section 417 of the Penal Code 1871 (2020 Rev Ed) (“PC”) into opening a new bank account in her name by deceiving the bank into believing that she would be the sole operator of the bank account when it was for the purpose of handing over the account to Mr Rafiez: see [3(b)], above;

(b) a mirror and similar charge under section 3(1) CMA for granting Mr Rafiez access to her existing bank account by passing the debit card and PIN number for that account to him: see [3(c)], above; and

(c) a charge of cheating another bank under section 417 PC into opening a second bank account in her name, a similar charge under section 3(1) CMA for granting Mr Rafiez access to that account via her Singpass account, and a similar charge under section 55A(1)(a)(i) read with section 55A(1)(b)(ii) CDSA of entering into an arrangement by handing over control of that account.

5 Ms Nooryati has dated property-related theft antecedents and unrelated drug antecedents. The prosecution has sought to impose a global sentence of more than eight to nine months’ imprisonment and a disgorgement fine of S$50. The defence has submitted a slightly shorter imprisonment term of six months and two weeks to six months and four weeks with the disgorgement fine.

6 I convicted Ms Nooryati on 8 September 2026 and having reserved my judgment on sentence after hearing parties on mitigation and sentence, as well as further submissions from the parties today, I now sentence her to six months’ and six weeks’ imprisonment with a disgorgement fine of S$50. I set out the reasons for my decision.

7 I preface my explanation on the sentences for the CMA and CDSA scams-related offences by identifying deterrence as the operative sentencing principle.

8 General deterrence continues to be the operative sentencing principle for scams-related offences, given the unabated rise in such offences at the time of the offences in April and May 2025. As I noted in PP v Shawn Loh [2025] SGDC 292 at [65]:

(a) scams were by far the most prevalent crime type in Singapore at the time;

(b) between 2020 and the first half of 2025, there were about 190,000 reported cases constituting 60% of all reported crimes, with losses amounting to about S$3.7bn; and

(c) scams-related offences reached a high watermark in 2024 with a seven-fold increase in losses to scams to at least S$1.1bn.

I acknowledged a brief respite in this dire situation in PP v Ayu Syakirah Binte Shahrul [2026] SGDC 111 at [15]. Although the number of scam cases eventually fell by 27.6% to 47,308 cases in 2025 from 51,501 cases in 2024, and the losses from scams also fell by 17.9% to about S$913.1m in 2025 from about S$1,112.4m in 2024, the situation was still very concerning and tackling scams remained a key priority. The decrease in both scam cases and scam losses suggested cautiously that the anti-scam strategies and public measures introduced by the Government and industry partners had made it more challenging for scammers to succeed. In tandem with such efforts, and so as not to undo this modest improvement and to prevent a reversal of this encouraging but nascent trend, the court continued to signal its deterrent stance against such serious offences categorically. This was prescient; indeed, the scam situation in Singapore improved further in the first half of 2026, continuing the downward trend since 2025. ¹

9 The rationale for targeting money mules at the source with the aim of disrupting the scam syndicates’ mode of operation was recently elucidated by the High Court in Mohammad Erzan Taib Zohri v PP [2026] SGHC 183 (“Erzan”) at [2]:

10 Specific deterrence is also implicated in Ms Nooryati’s case because of her recalcitrant offending behaviour evinced by the multiplicity of her offences.

11 Because the bank accounts were used to launder scam proceeds, I agree with the parties that regard could be had to the Sentencing Advisory Panel’s guidelines on scams-related offences, subject to the clarifications made in Erzan’s case. In this regard, the High Court set a benchmark sentence for an archetypal CDSA bank account relinquishment offence. It also decided that the sentencing framework prescribed by the guidelines for such offences can apply to legacy cases prosecuted under the CMA: Erzan at [107], and similarly set a benchmark sentence for such CMA offences.

12  After opening a new bank account, Ms Nooryati granted Mr Rafiez access to that account by passing the bank card for the account to him, thereby abetting the unauthorised access of computer material by aiding him in this manner.

13 Sometime in April 2025, Mr Rafiez had offered Ms Nooryati “fast cash” in exchange for a new bank account to be opened in her name. Misguided by her drug addiction, she accepted the offer and duly opened a new account on 15 April 2025, and passed the bank card for the account to Mr Rafiez. She did not ascertain his purpose for taking control over the account before ceding such control to him. The account was then used to launder S$167,364.71 and there is no evidence that the account was used to make any legitimate transactions after Ms Nooryati ceded its control to Mr Rafiez.

14 For the CMA offence, Ms Nooryati faces a fine not exceeding S$5,000 and/or imprisonment not exceeding two years by virtue of section 3(1)(a) CMA. The prosecution has sought a sentence of more than 18 weeks’ imprisonment to be imposed on her whereas the defence three to three-and-a-half months’ imprisonment.

15 Given that the conduct of relinquishment of bank accounts previously prosecuted under the CMA is the same as that of handing over control of bank accounts now prosecuted under the CDSA, and that the legacy CMA offences tackle the same social menace of scams and its enablement by bank account relinquishment as the new regime CDSA offences: Erzan at [106], the High Court set a benchmark sentence of three to four months’ imprisonment for a bank relinquishment offence prosecuted under the CMA, given its lower statutory maximum of two years’ imprisonment as compared to three years’ imprisonment for an offence prosecuted under the CDSA: Erzan at [109]. The High Court clarified that the archetypal case attracting the benchmark sentence should feature an offender being motivated by gain: Erzan at [88].

16 In Ms Nooryati’s case, she relinquished a new account she had opened to Mr Rafiez. She chose to ignore the purpose for which he needed the account because she was motivated by financial gain to feed her addiction, as is evident from her adject failure to make enquiries as to the reason for him controlling the bank account before ceding such control to him. The bank account was later used to launder illegitimate funds. The benchmark sentence of four months’ imprisonment therefore applies in Ms Nooryati’s case.

17 An overall uplift of two months’ imprisonment from the benchmark sentence is justified on the basis that:

(a) she opened a new bank account for the purpose of handing over the account to Mr Rafiez. This is an offence-specific aggravating factor to reflect the fact that she had both induced the bank to open a bank account for the use of an unauthorised person and relinquished the bank account to that unauthorised person: Erzan at [110]. This warranted an uplift of one month’s imprisonment; and

(b) because a significant amount of funds totalling S$167,364.71 was laundered through the relinquished account, a further uplift of one month’s imprisonment from the benchmark sentence is warranted: Erzan at [90]; see also Galvez Mary Jow Blanco v PP [2026] 3 SLR 1427 at [58]. As Ms Nooryati choose to ignore the purpose for which Mr Rafiez needed her account evinced by her failure to find out the reason for him controlling the account before she ceded such control to him: see [13], above, the use of the account for nefarious purposes, including syndicated laundering of criminal proceeds, and consequently the amount of funds, which were not legitimate at the very least, that flowed through the relinquished bank account, was foreseeable: Erzan at [90].

18 As I have already factored them in the sentence for the CDSA offence: see [28], below, I agree with the defence and have taken care not to double-count the TIC charges relating to Ms Nooryati opening and relinquishing the second new bank account by using them again to enhance the sentence for the CMA offence: Muhammad Sutarno bin Nasir v PP [2018] 2 SLR 647 at [17].

19 Although motivation by gain is part of the archetypal case and not to be considered a separate aggravating factor above and beyond the archetypal case, Ms Nooryati actually benefitted from her offending conduct in this case: Erzan at [92], [114] and [275(c)]. However, to the extent that she only received S$50, which she used to top up her EZ-Link card, in exchange for all the bank accounts she had relinquished, I do not think it is necessary to impose a further uplift from the benchmark sentence.

20 I accord to Ms Nooryati the full 30% reduction in sentence for her early indication of guilty plea following the recommendations of the Sentencing Advisory Panel in its guidelines in this regard.

21  The final sentence I arrive at and impose on Ms Nooryati’s CMA charge is therefore four months’ imprisonment.

22  Through liaising with Mr Rafiez as the point of contact, Ms Nooryati entered into an arrangement by handing over control of her existing bank account to unknown syndicate member persons without taking reasonable steps to ascertain their purpose of accessing her account.

23 On 25 April 2025, Ms Nooryati opened a second bank account on the instructions of Mr Rafiez, who informed her that the first bank account had “problem”, and granted him access to that second account via her Singpass account. The second account was used to launder a total of S$20,053.80, of which S$17,990 was traced to a government official impersonal scam perpetrated on a vulnerable 77-year-old victim. This was the subject matter of three CDSA, CMA and cheating TIC charges arising from this same set of facts.

24 On or about 21 May 2025, Ms Nooryati passed the debit card and PIN number for her existing bank account to Mr Rafiez, after he had informed her that the second bank account she opened “cannot be used”. That existing bank account was later used to launder scams proceeds amounting to S$126,515 traceable to a 55-year-old victim. Likewise, Ms Nooryati did not find out Mr Rafiez’s purpose of taking control of the account before ceding such control to him; there is no evidence that the account was used to make legitimate transactions after Ms Nooryati ceded its control to him. Ms Nooryati therefore did not take reasonable steps to ascertain the purpose of the unknown syndicate member persons accessing the bank account.

25 For the CDSA offence, Ms Nooryati faces a fine not exceeding S$50,000 and/or imprisonment not exceeding three years by virtue of section 55A(5) CDSA. The prosecution has sought a sentence of more than six months’ imprisonment to be imposed on her whereas the defence six months’ imprisonment.

26 The benchmark sentence for an archetypal case, where an offender:

(a)  hands over control of an existing bank account to another person,

(b) does so with the requisite mental element prescribed by the CDSA,

(c) is motivated by gain whether or not such a gain actually materialises, and

(d) the bank account is later used to receive and transfer funds which are benefits of crime,

is six months’ imprisonment for a first-time offender on a claim-trial basis: Erzan at [88]. As Ms Nooryati’s case fell on all fours with the archetypal case, the benchmark sentence of six months’ imprisonment therefore applies in her case.

27 Likewise, an uplift of one-and-a-half months’ imprisonment (or 25% of the starting point sentence) from the benchmark sentence is justified on the basis that a significant amount of scam proceeds to the tune of S$126,515 was laundered: see [17(b)], above.

28 Because Ms Nooryati opened a second bank account to be handed over that was later used to launder scam proceeds and a vulnerable victim was implicated, a further uplift of one-and-a-half months’ imprisonment was warranted.

29 Likewise, I do not think it necessary to impose a further uplift from the benchmark sentence to account for Ms Nooryati actually benefitting from her offences: see [19], above. I impose a fine of S$50 to disgorge the benefits that she had received from committing the bank account relinquishment offences.

30 I accord to Ms Nooryati the full 30% reduction in sentence for her early indication of guilty plea following the recommendations of the Sentencing Advisory Panel in its guidelines in this regard.

31  The final sentence I arrive at and impose for Ms Nooryati’s CDSA offence is therefore six months’ imprisonment and a disgorgement fine of S$50.

32 Ms Nooryati parted possession with her identity card to Mr Rafiez.

33 Deterrence is also the dominant sentencing principle for Ms Nooryati’s NRA offence. The court in PP v Tan Woon Keng [2006] SGDC 184 explained at [15] as such:

34 In Ms Nooryati’s case, given the backdrop of the scams-related offences where she had relinquished or handed over control of various bank accounts by using her identity card and Singpass account, these observations in Tan Woon Keng, which were made in the context of a syndicated offence of misuse of another’s identity card, are germane: Xu Zhaohe v PP [2012] 3 SLR 918 at [4]. Such offences would cast a long shadow over the integrity of the entire identity card system if it were to proliferate and I am cognisant of the nature of the particular NRA offence committed by Ms Nooryati and why she committed it: Xu Zhaohe at [6].

35 Sometime in May 2025, Ms Nooryati handed over her identity card to Mr Rafiez when he informed her that he needed it due to an unsuccessful bank account application. This was against the backdrop of Ms Nooryati using her identity card and Singpass account to set up various bank accounts together with Mr Rafiez for the syndicated scams-related offences. Subsequently, on 27 May 2025, she lodged a police report after he failed to return her identity card despite repeated calls for him to do so over the course of a week.

36 For the NRA offence, Ms Nooryati faces a fine not exceeding S$10,000 and/or imprisonment not exceeding ten years. The prosecution has sought an imprisonment term of two to three months to be imposed on her, whereas the defence a term of two to four weeks’ imprisonment instead.

37 The prosecution has submitted that reference should be taken from the benchmark sentence of three months’ imprisonment declared in Tan Woon Kheng at [19] for abetting the offence of possession of an identity card under section 13(1)(d) NRA (Cap 201, 1992 Rev Ed) (“NRA 1992”). The defence has suggested the approach of looking to previous section 13(2)(a) NRA 1992 cases for guidance instead.

38 The prosecution has submitted that the starting point for Ms Nooryati’s NRA offence would be the three-month imprisonment benchmark sentence declared in Tan Woon Kheng at [19], where the purpose is to further the commission of an offence, for which a custodial sentence is undeniably warranted. The prosecution also relied on the court’s observation at [11] that the accused in that case could have been charged for an offence of unlawfully parting with his identity card and further submitted that even though it attracted different punishment, the essence of the two offences is the same.

39 I hold a different view. First, the declaratory basis for the benchmark sentence in Tan Woon Kheng is, with respect, not clear to me. Second, the fact of the matter is that the accused in Tan Woon Kheng could have been, but was in actual fact not prosecuted under the predecessor section 13(2)(a) NRA 1992, with the court proceeding to sentence him on the basis of the lesser section 13(1)(d) NRA 1992 offence for which he was charged. Third, that Ms Nooryati’s NRA offence is to be found in a different sub-section of the section 13 NRA offence provision altogether does not merely mean that graver punishment is attracted and nothing more; to the extent that I agree with the defence that it would otherwise be tautologous to have different offences appear differently within the same provision attracting different punishments, I do not think the essence of the offences of unlawful possession of an identity card and the unlawful parting with its possession is the same, at least not on any much broader generalisation (necessitated by such an argument) that would be helpful to the present analysis.

40 I therefore prefer the defence’s approach of looking to previous section 13(2)(a) NRA 1992 cases for guidance. PP v Sim Guan Liang James [2016] SGDC 92 is one such case cited by the prosecution that the defence has sought to distinguish, where the accused was involved in syndicated identity trafficking by handing over his identity card for financial gain to sponsor visa applications for Chinese nationals who wanted to come to Singapore. Suffice it to say that the court in that case did not elucidate why it agreed at [86] with the prosecution’s submission at [85] that:

As such, I continue to hold my earlier reservation about such an argument: see [39], above, and found this case to be of limited assistance to the prosecution.

41 I also referred parties to several other section 13(2)(a) NRA 1992 cases, namely PP v Saw Hock Ling Victor Cecil [2005] SGDC 162 (“Victor Saw”), PP v Tan Wan Wen [2005] SGDC 185 and PP v Koh Liang Hock [2009] SGDC 230, and a section 16(2)(a) NRA case, PP v Muhammad Mikail Bin Zali, unreported, District Arrest Case No 913856 of 2023 (“Mikail”).

42 Victor Saw involved the sale of identity cards (and travel documents) to criminal syndicates who would obviously use them to illegally circumvent control measures either in Singapore or overseas: Victor Saw at [8]. This is tantamount to criminal acts facilitating or supporting the proliferation of organised illegal migration offences that would amount to a fraud on the authorities: Victor Saw at [9]. A sentence of three months’ imprisonment was imposed on the section 13(2)(a) NRA offence. Tan Wan Wen is a related case. The accused sold her identity card for gain to a chatline friend through a third party. She introduced that friend to the accused in Victor Saw. An imprisonment term of three months was also imposed on the section 13(2)(a) NRA 1992 offence. Last, Koh Liang Hock involved the accused parting with his identity card, which facilitated the illegal act of extending the social visit pass of a foreign national on false pretences, for gain. An imprisonment term of ten weeks’ imprisonment was imposed.

43 All three cases involved the sale of identity cards for gain. They were also syndicated and implicated the wider public interest against facilitating the commission of immigration offences. In contrast, while she previously handed her identity card and provided her Singpass details to Mr Rafiez to purchase SIM cards as she needed money to feed her drug habit, Ms Nooryati handed her identity card on this occasion to him because he told her that he needed her physical identity card due to an unsuccessful bank account application, albeit in the context of them setting up various bank accounts together in relation to the scams-related offences against the backdrop of syndicates operating in the background.

44 The sentence of two to four weeks’ imprisonment that the defence has sought is not unprecedented. Mikail involved a 22-year-old youthful offender, who parted possession with his identity card that was used to register for SIM cards for gain. The SIM cards were later used to perpetrate spoofing scams. The prosecution in that case sought for a short custodial term and a sentence of two weeks’ imprisonment was imposed for the section 16(2)(a) NRA offence.

45 Although the case is unreported, I am equally well placed and perfectly entitled to arrive at the same sentence on an independent assessment of the facts of the case that are available to me, mainly the accused person’s youth and therefore rehabilitative prospects. He was enticed by the fast cash offered by his casual acquaintance in exchange for his identity card to be given to a third party who would use it to register for SIM cards. In Ms Nooryati’s case, although she is not a youthful offender and ought to have known better as an adult, decidedly in her favour is the fact that she had lodged a police report within the same month of parting with possession of her identity card after calling Mr Rafiez repeatedly for a week to return her identity card but to no avail. This is unlike the accused persons in the precedent cases who had lodged police reports only because they felt they had been cheated when they were not paid the promised reward for their efforts: see eg Tan Wan Wen at [19].

46 I have already taken general cognisance of Ms Nooryati’s past conduct of handing over her identity card to Mr Rafiez for gain as background context, but I am not prepared to accord any further weight to this that will enhance her culpability for the NRA offence. Having regard to the nature of her NRA offence and why she committed the offence, coupled with the fact that she lodged a police report that ultimately implicated herself, I impose a term of six weeks’ imprisonment on Ms Nooryati’s NRA charge.

47 The individual sentences I impose on each charge proceeded against Ms Nooryati are:

(a) CMA offence: four months’ imprisonment

(b) CDSA offence: six months’ imprisonment with a disgorgement fine of $50

(c) NRA offence: six weeks’ imprisonment

48 As Ms Nooryati has been convicted of three or more distinct offences, the sentences on at least two of them must run consecutively. I agree with the parties that I should run only two sentences consecutively. Her overall criminality can be encompassed by two consecutive sentences. I order the sentences on her CDSA and NRA charges to run consecutively with the sentence on the CMA charge to run concurrently.

49 I therefore sentence Ms Nooryati to an aggregate term of six months’ and six weeks’ imprisonment with effect from today with a fine of $50 to disgorge the financial benefit she had received for her crime. If she does not pay the fine, she will serve one day’s imprisonment in default. The aggregate sentence is sufficient. It is also not crushing and it is proportionate.