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Anti-Corruption

Singapore: CCCS obtains court orders against immigration consultancy businesses for unfair trade practices

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In brief

On 11 August 2025, the Competition and Consumer Commission of Singapore (CCCS) announced that it had obtained court orders against various immigration consultancy businesses for engaging in misleading trade practices.

This case marked the CCCS’ first court action against an individual who used new business entities to evade detection of unfair trade practices.

In more detail

CCCS’ investigations

The CCCS commenced investigations into an immigration consultancy business after receiving multiple consumer complaints regarding misleading sale tactics. Upon discovering the mastermind behind the unfair trade practices, the CCCS then shifted its focus to other immigration consultancy businesses directed by the same individual.

The CCCS’ investigations uncovered the following:

  • After potential customers completed forms online to check their chances of obtaining permanent residency (PR), they would be invited for “free consultations”. During these consultations, sales staff would make unsubstantiated claims about rapidly changing PR rules and intense competition from other applicants to try to persuade customers to apply as soon as possible.
  • Sales staff would also make baseless guarantees of PR application approval if customers engaged their services.

The CCCS found that there was no reasonable basis for the businesses to make these claims or guarantees, and deemed these actions to be unfair trade practices under the Consumer Protection (Fair Trading) Act 2003 (CPFTA).

The investigations also revealed that the individual responsible for directing the operations of the businesses was deliberate in implementing the misleading practices. The individual personally wrote scripts on what staff members needed to do or say to prospective customers; monitored staff’s sales tactics through CCTV footage; and implemented a punishment-and-reward system to enforce his staff’s compliance with such misleading practices.

Further, the CCCS found that the individual continued to operate through their other businesses to evade detection, despite ongoing CCCS investigations into some of their closed businesses.

Court orders

The District Court ordered the individual and the relevant businesses to do the following:

  • Cease the unfair trade practices
  • Publish details of the court orders on their online marketing platforms and in major newspapers in Singapore
  • Inform potential customers about the court orders prior to contracting with them
  • Notify the CCCS of any changes to the business structures and the individual’s employment, control or ownership of the businesses

Failure to comply with the court’s order may result in the individuals and the relevant businesses being found in contempt of court.

Key takeaways

This case demonstrates the CCCS’ strict enforcement stance against individuals who use new business entities to evade detection of unfair trade practices.

This case follows other recent CCCS enforcement actions against businesses for unfair trade practices (see our previous client alerts from August 2025 and July 2025 for more details), and we expect this regulatory scrutiny and strict enforcement to continue. This case is a timely reminder for businesses to ensure their marketing practices remain transparent and compliant with the CPFTA.

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Andy Leck is a distinguished senior legal practitioner in Intellectual Property and Technology, Media and Telecommunications (TMT) matters. He is the head of the Intellectual Property and Technology (IPTech) Practice Group in Singapore, and serves as the Asia Pacific head of Baker McKenzie's TMT Industry Group. Andy is widely recognized by reputable global industry and legal publications as a leader in his field. He was named on "The A-List: Singapore's Top 100 lawyers" by Asia Business Law Journal since 2018. Chambers Asia Pacific notes that Andy as "a well-known IP practitioner who is highlighted for his record of handling major trade mark litigation, as well as commercial exploitation of IP rights in the media and technology sectors. He's been in the industry for a long time and has always been held in high regard. He is known to be very fair and is someone you would like to be in the trenches with you during negotiations." Furthermore, Asian Legal Business acknowledges Andy as a leading practitioner in his field and notes that he “always gives good, quick advice, [is] client-focused and has strong technical knowledge for his areas of practice.” Under his leadership, the TMT team in Singapore is highly regarded for its expertise in “outsourcing, cloud computing and TMT IP-related mandates” and “data privacy, compliance, technology and telecoms regulations.” Andy was appointed by the Intellectual Property Office of Singapore (IPOS) as an IP Adjudicator to hear IP disputes between 2021 and 2023. He has been an appointed member of the Singapore Copyright Tribunal since May 2010 and a mediator with the WIPO Arbitration and Mediation Center, as well as the Singapore Mediation Centre.

Author

Ren Jun Lim is a principal with Baker McKenzie Wong & Leow. He represents local and international clients in both contentious and non-contentious intellectual property matters. He also advises on a full range of healthcare, as well as consumer goods-related legal and regulatory issues. Ren Jun co-leads Baker McKenzie Wong & Leow's Healthcare as well as Consumer Goods & Retail industry groups. He sits on the Law Society of Singapore IP Committee and on the Executive Committee of the Association of Information Security Professionals. He is also a member of the Vaccines Working Group, Singapore Association of Pharmaceutical Industries, a member of the International Trademark Association, as well as a member of the Regulatory Affairs Professionals Association. Ren Jun is ranked in the Silver tier for Individuals: Enforcement and Litigation and Individuals: Prosecution and Strategy, and a recommended lawyer for Individuals: Transactions by WTR 1000, 2020. He is also listed in Asia IP's Best 50 IP Expert, 2020, recognised as a Rising Star by Managing IP: IP Stars, 2019 and one of Singapore's 70 most influential lawyers aged 40 and under by Singapore Business Review, 2016. Ren Jun was acknowledged by WTR 1000 as a "trademark connoisseur who boasts supplementary knowledge of regulatory issues in the consumer products industry." He was also commended by clients for being "very responsive to enquiries and with a keen eye for detail, he is extremely hands-on. His meticulous and in-depth approach to strategising is key to the excellent outcomes we enjoy."

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