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The Monetary Authority of Singapore (MAS) has imposed a civil penalty of S$50,000 on a 56-year-old-man, Tan Tee Beng (“Tan”), for insider trading in the shares of Tee International Limited (“Tee International”) and Tee Land Limited (“Tee Land”). This civil penalty follows a joint investigation by the CAD and the MAS.

On 13 January 2020, Tee International announced that it had entered into a conditional sale and purchase agreement to sell its entire stake in its subsidiary, Tee Land to Amcorp Supreme Pte Ltd at S$0.179 per share. This sale price represented a premium of 9.1% over the closing price of Tee Land shares at S$0.164 on the previous trading day.

At the material time, Tan was the Head of Margin at RHB Securities Singapore Pte Ltd (“RHB Securities”) [1]. In the course of his work, Tan came to know of Tee International’s impending sale of Tee Land and its intended sale price before this information was made public. 

Tan saw this corporate transaction as positive news and believed that the market would react positively to it. On 16 October 2019, he procured an individual to purchase shares in Tee International and Tee Land. On 11 and 13 December 2019, he personally purchased three million shares in Tee International. The Tee Land sale was eventually announced on 13 January 2020. 

Tan has admitted to contravening section 219(2)(a) and section 219(2)(b) of the Securities and Futures Act (Chapter 289, Revised Edition 2006) (“SFA”) and has paid MAS the civil penalty without court action. Tan has also given a voluntary undertaking not to be a company director or be involved in the management of a company for a period of two years. 

Additional information

(A) The civil penalty regime

A civil penalty action is not a criminal action and does not attract criminal sanctions. The civil penalty regime, designed to complement criminal sanctions and provide a nuanced approach to combat market misconduct, became operational at the beginning of 2004.

Under section 232 of the SFA, MAS may enter into an agreement with any person for that person to pay, with or without admission of liability, a civil penalty for contravening any provision of Part 12 of the SFA. The civil penalty may be up to three times the amount of the profit gained or loss avoided by that person as a result of the contravention, subject to a minimum of $50,000 (if the person is not a corporation) or $100,000 (if the person is a corporation).

(B) Section 219(2)(a) of the SFA

Section 219(2)(a) prohibits a person who is not connected to any corporation but who possesses materially price-sensitive information that is not generally available, which he knows is materially price-sensitive and not generally available, from subscribing for, purchasing or selling, or entering into an agreement to subscribe for, purchase or sell these securities.

(C) Section 219(2)(b) of the SFA

Section 219(2)(b) prohibits a person who is not connected to any corporation but who possesses materially price-sensitive information that is not generally available, which he knows is materially price-sensitive and not generally available, from procuring another person to subscribe for, purchase or sell, or enter into an agreement to subscribe for, purchase or sell these securities.

[1]: RHB Securities is no longer in operation.