Your last para is not accurate as far as I know. 1) ABSD is paid by the owner of the property, in this case the UBS Nominee Account. UBS holds the property in their name on behalf of the beneficiary. Therefore, UBS pays the ABSD and hence the beneficiary is still unknown. 2) MAS has no access to account holder and beneficiary's details unless they specifically file a formal request for it. As long as UBS says their AML vetted the funds and therefore did not have to report STRO because it was clean, there is usually no reason for MAS to check. In any case, the co-ordinating agency to do all this is CPIB or CAD, where they will put together all the various agencies information. In fact, MAS can easily ask for the account number of the Nominee account and then see which account $88 million flowed from. That will determine who is the beneficial owner. But all this is moot. The bosses of these agencies are not independent and no one wants to fuck with the most vindictive minister.