Regulatory Oversight and Professional Ethics in Private Investigation: An Analysis of Public Prosecutor v. Tan Hui Ting & Tan Kok Boon in Singapore
Abstract
This paper examines the recent charging of two private investigation agency partners in Singapore for allegedly providing services without proper authorization, particularly involving surveillance within a protected place. Drawing on the facts presented in the news report, this analysis delves into the legal framework governing private security and investigation in Singapore, specifically the Private Security Industry Act (PSIA) and the Infrastructure Protection Act (IPA). It discusses the significant regulatory lapses, the profound ethical implications of surveilling a police officer involved in an active investigation, and the broader ramifications for the private security industry. The paper argues that this “first case of its kind” underscores the critical need for strict adherence to regulatory protocols, robust professional ethics, and heightened accountability within the sector to safeguard public interest and national security.
- Introduction
The global landscape of security and investigation services has witnessed a dynamic expansion of private actors operating alongside state-run law enforcement agencies. While private investigation (PI) services offer valuable support in various civil and criminal matters, their operations are inherently sensitive, impinging on privacy, public order, and occasionally, national security. Consequently, robust regulatory frameworks are essential to govern their conduct, ensure accountability, and prevent abuse of power.
This paper focuses on a particularly salient case in Singapore, reported on October 30, 2025, concerning the charging of two partners of a licensed private investigation agency. Tan Hui Ting, 32, and Tan Kok Boon, 57, face charges under the Private Security Industry Act (PSIA) for allegedly providing surveillance services without obtaining the requisite approval, specifically within the Police Cantonment Complex, a designated protected place under the Infrastructure Protection Act (IPA). This incident, highlighted as the “first case of its kind” by the authorities, provides a crucial lens through which to examine the intricate balance between the provision of private investigative services, regulatory compliance, and professional ethics in a highly secured jurisdiction.
This paper aims to:
Detail the factual matrix of the case as reported.
Explicate the relevant legal framework, namely the PSIA and IPA, that governs private investigation services and protected places in Singapore.
Analyze the regulatory lapses and ethical implications arising from the alleged conduct.
Discuss the broader implications of this precedent-setting case for the private security industry, law enforcement, and public policy in Singapore.
- Case Overview: Public Prosecutor v. Tan Hui Ting & Tan Kok Boon
According to the police statement released on October 30, 2025, the case originated when an individual engaged a licensed private investigation agency to conduct surveillance on a police officer. This officer was reportedly involved in an investigation pertaining to the client’s family member. The two partners of the agency, Tan Hui Ting and Tan Kok Boon, accepted this assignment and deployed four private investigators to conduct surveillance, which included trailing the police officer at both his home and workplace.
The critical element of the alleged offense stems from the location of the surveillance. The police officer’s workplace was identified as the Police Cantonment Complex. This facility is explicitly designated as a “protected place” under Singapore’s Infrastructure Protection Act (IPA). Consequently, “prior approval from the Police Regulatory Department is required under the Private Security Industry Act” for any private investigation services conducted within such a locale. The police statement unequivocally asserted that the partners “had accepted and carried out the assignment without obtaining the necessary approval.” As a result, both Tan Hui Ting and Tan Kok Boon were formally charged on October 30, 2025, facing a total of four charges, including those under the Private Security Industry Act.
This case is particularly noteworthy as authorities have characterized it as the “first case of its kind,” implying a novel application or enforcement action within Singapore’s regulatory landscape for private investigators.
- Legal Framework: The Private Security Industry Act (PSIA) and Infrastructure Protection Act (IPA)
Singapore has established a robust legal framework to regulate the security industry, including private investigation services, to ensure public safety, order, and national security. The two primary statutes pertinent to this case are the Private Security Industry Act (Cap. 254A) and the Infrastructure Protection Act (No. 42 of 2017).
3.1. The Private Security Industry Act (PSIA)
Enacted to regulate the private security industry, the PSIA mandates that individuals and companies providing security services, including private investigation, must be licensed by the Police Licensing and Regulatory Department (PLRD). The Act aims to professionalize the industry, ensure accountability, and prevent unauthorized or undesirable individuals from engaging in security-sensitive work.
Key provisions of the PSIA relevant to this case include:
Licensing Requirements: Individuals working as private investigators and the agencies employing them must hold valid licenses. These licenses come with conditions and responsibilities, including adherence to ethical guidelines and legal boundaries.
Regulation of Services: The Act delineates the scope of permissible services and the manner in which they can be conducted. Any deviation or engagement in activities beyond the authorized scope or without necessary permits constitutes a breach.
Specific Approvals: The police statement explicitly notes that “prior approval from the Police Regulatory Department is required under the Private Security Industry Act” for operations within “protected places.” This highlights a specific regulatory hurdle designed to control access and activity in sensitive government or critical infrastructure locations, even for licensed PIs. The failure to secure such approval, as alleged in this case, represents a direct contravention of the Act’s licensing conditions and operational mandates.
Penalties: The PSIA prescribes penalties for various offenses, including operating without a license, breaching license conditions, or failing to comply with directives, which can include fines, imprisonment, and suspension or revocation of licenses.
3.2. The Infrastructure Protection Act (IPA)
The Infrastructure Protection Act (IPA) was introduced to enhance the security of critical infrastructure, particularly against terrorism and other serious threats. It empowers the Minister for Home Affairs to designate premises as “protected places” or “critical infrastructure,” thereby imposing stringent security requirements and access controls.
Key aspects of the IPA relevant to this discussion are:
Designation of Protected Places: The Police Cantonment Complex, as the headquarters for the Singapore Police Force, is a highly sensitive location, and its designation as a “protected place” under the IPA is logical and necessary for national security.
Enhanced Security Measures: For protected places, the IPA allows for stricter control over entry, movement, and activities within their precincts. This includes the authority to search individuals and vehicles, regulate photography, and restrict unauthorized surveillance.
Prohibited Activities: The Act implicitly or explicitly prohibits unauthorized activities that could compromise the security of these sites. Surveillance, especially by private entities without explicit authorization, falls squarely into this category. The act of trailing a police officer at such a location, without approval, can be construed as an attempt to gather intelligence on personnel and operations, posing a potential security risk.
Penalties: The IPA carries severe penalties for unauthorized entry, breaches of security, or engagement in prohibited activities within protected places, reflecting the high importance placed on safeguarding these sites. While the specific charges against the partners were under the PSIA, the context of the IPA significantly elevates the gravity of their alleged conduct.
3.3. Synergy of PSIA and IPA
The confluence of the PSIA and IPA in this case underscores Singapore’s comprehensive approach to security governance. The PSIA regulates who can provide PI services and how, while the IPA delineates where such services, especially sensitive ones, are permissible. The requirement for approval under the PSIA for operations within IPA-designated protected places creates a powerful regulatory synergy. It ensures that even licensed private investigators, operating with legitimate aims, must navigate a higher bar of scrutiny and authorization when their activities intersect with critical national security infrastructure. The alleged disregard for this integrated regulatory mechanism forms the core of the charges against Tan Hui Ting and Tan Kok Boon.
- Analysis and Discussion: Regulatory Lapses and Ethical Implications
The case of Public Prosecutor v. Tan Hui Ting & Tan Kok Boon illuminates significant regulatory lapses and profound ethical dilemmas within the private investigation industry.
4.1. Regulatory Non-Compliance and Due Diligence Failures
The most direct violation alleged is the failure to obtain “prior approval from the Police Regulatory Department” for conducting surveillance at the Police Cantonment Complex. This suggests a critical breakdown in due diligence and adherence to statutory requirements on the part of the PI agency and its partners.
Ignorance vs. Intent: Was this an oversight or a deliberate disregard of regulations? As partners in a licensed agency, they are expected to be fully conversant with the legal and regulatory landscape governing their operations, especially concerning sensitive locations. Ignorance of the law is generally not a defense.
Professional Responsibility: Licensed professionals, particularly in fields affecting public safety and security, bear a heightened responsibility to ensure compliance. The partners’ alleged failure to verify the necessity of approval before accepting and executing the assignment reflects a serious lapse in their professional obligations.
Agency Accountability: The charges against the partners, as opposed to solely the individual investigators, emphasize the corporate responsibility of the agency. This signals that ultimate accountability for regulatory compliance rests with the leadership of private security firms.
4.2. Ethical Dimensions of Surveilling a Police Officer
Beyond the regulatory breach, the ethical implications of the assignment itself are substantial:
Potential for Obstruction of Justice/Intimidation: The client’s stated objective was surveillance on a police officer investigating a case involving the client’s family member. Such an action, regardless of stated intent, carries the inherent risk of intimidating the officer, interfering with an ongoing investigation, or attempting to gather information for improper purposes (e.g., to discredit the officer or compromise the investigation). This blurs the lines between legitimate evidence gathering and potentially subversive tactics.
Conflict with Public Interest: Police officers serve the public interest by upholding the law. Unauthorized private surveillance of a police officer, particularly one engaged in an official capacity, can be seen as undermining law enforcement efforts and public trust in the justice system. The private interests of a client should not supersede the public duty of law enforcement, especially when conducted by regulated private entities.
Professional Boundaries: Private investigators operate within a specific mandate, often complementing law enforcement but never supplanting or interfering with it. The act of turning investigative tools against a public servant, particular
ly without authorization and within a sensitive context, represents a significant breach of professional boundaries.
Risk to Officer Safety and Privacy: Trailing an officer at home and workplace invades their personal privacy and could potentially expose them or their family to risk, regardless of the client’s stated intentions. This raises questions about the ethical limits of surveillance techniques and the duty of care PIs owe even to those they are investigating.
4.3. The “Protected Place” Conundrum
The fact that surveillance occurred at the Police Cantonment Complex – a “protected place” – amplifies the gravity of the transgression:
National Security Implications: Protected places, by their very definition under the IPA, are critical to national security or the functioning of essential services. Unauthorized surveillance within such a facility could compromise operational security, reveal sensitive information, or be perceived as a precursor to more serious security breaches. Even if the intent was solely related to the family member’s case, the act itself carries a significant security risk.
Symbolic Importance: The Police Cantonment Complex is a symbol of state authority and law enforcement. Unauthorized private surveillance there represents a challenge to state control and authority over its critical assets and personnel.
4.4. Precedent Setting and Industry Impact
The police statement’s characterization of this as the “first case of its kind” is particularly significant:
Clear Warning Signal: It sends a strong deterrent message to the entire private security industry in Singapore that such violations will be met with firm prosecutorial action. This case will likely serve as a benchmark for future enforcement.
Increased Scrutiny: The incident may lead to increased scrutiny of PI licensing processes, operational protocols, and mandatory training requirements to ensure better awareness and compliance with regulations concerning protected places and sensitive assignments.
Reputation of the Industry: While individual actions, this case can cast a shadow on the perceived professionalism and integrity of the broader private investigation industry. It underscores the need for industry associations to reinforce ethical codes and best practices.
- Implications and Recommendations
This case carries significant implications for various stakeholders:
5.1. For the Private Security Industry
Enhanced Training and Awareness: There is an urgent need for all licensed private investigation agencies and their personnel to undergo rigorous training on the full scope of the PSIA, IPA, and other relevant statutes. Specific emphasis should be placed on identifying “protected places” and understanding the mandatory approval processes.
Robust Internal Protocols: Agencies must implement stringent internal review processes for accepting assignments, especially those involving sensitive targets (e.g., public officials) or locations (e.g., protected places). A multi-tiered approval system, perhaps involving legal counsel, could mitigate risks.
Professional Ethics: Industry bodies should reinforce and disseminate clear ethical guidelines, emphasizing the imperative to avoid conflicts of interest, prevent obstruction of justice, and respect the privacy and safety of all individuals, even those under investigation.
Due Diligence: A culture of proactive due diligence should be fostered, where the legality and ethical implications of every assignment are thoroughly vetted before execution.
5.2. For Law Enforcement and Regulatory Bodies
Clarification of Guidelines: The PLRD may consider issuing clearer, more detailed guidelines or public advisories to PI agencies regarding operations near or within protected places, specifically addressing scenarios involving surveillance of public officials.
Enforcement Vigilance: This case demonstrates the PLRD’s commitment to enforcing security legislation. Continued vigilance and prompt action against non-compliant entities are crucial to maintaining the integrity of the private security landscape.
Review of Approval Processes: While approval is required, the process itself could be reviewed for efficiency and clarity to ensure that legitimate requests are handled transparently, while preventing unauthorized activities.
5.3. For Public Policy and Governance
Balancing Interests: The case highlights the perennial challenge of balancing the legitimate needs for private investigation services with the imperative to protect public officials, critical infrastructure, and the integrity of the justice system.
Strengthening Synergy: The combined power of the PSIA and IPA needs to be consistently underscored and enforced to ensure a coherent and robust national security framework.
Public Awareness: While focused on PIs, the case also raises public awareness about the limits of private surveillance and the mechanisms in place to protect sensitive locations and personnel.
- Conclusion
The charging of Tan Hui Ting and Tan Kok Boon in Singapore for allegedly conducting unauthorized private investigation services, particularly involving surveillance of a police officer at a protected place, constitutes a landmark event. This “first case of its kind” unequivocally underscores the stringent regulatory environment in Singapore, particularly through the Private Security Industry Act and the Infrastructure Protection Act.
The alleged actions represent not only a critical failure in regulatory compliance but also raise serious ethical questions about the boundaries of private investigation, the potential for obstruction of justice, and the respect for public interest and national security. The case serves as a potent reminder to the entire private security industry in Singapore to prioritize rigorous adherence to legal mandates, cultivate a strong ethical compass, and exercise unwavering due diligence in all operational facets. For regulatory bodies, it reaffirms the importance of vigilant oversight and consistent enforcement to uphold the integrity of the security landscape. Ultimately, this incident reinforces the fundamental principle that even legitimate private activities must operate strictly within the confines of law and public interest, especially when interacting with the sensitive domains of law enforcement and critical national infrastructure.
References
The Straits Times. (2025, October 30). Pair charged after they allegedly provided private investigation services without approval. The Straits Times. Retrieved from [The provided text implies this is a fictional news article from Oct 30, 2025. As such, a direct URL cannot be provided. However, for academic purposes, it would be cited as a news article.]
SINGAPORE—In a shocking turn of events, a 70-year-old retiree fell victim to a cunning scam that cost her a staggering $200,000. Despite her years of worldly experience, fraudsters posing as foreign police officers ensnared her.
The scammers preyed on her deep-seated fears, particularly an irrational dread of being convicted for a crime she never committed. Incredibly, she had never even set foot in the country from which the scammers claimed to hail. Yet, the mere thought of facing legal repercussions overseas consumed her with anxiety.
Convinced that her credit card had been misused, she took drastic action. Trusting the fabricated authority of these so-called officers, she transferred her life savings to them for “safe-keeping.” It’s astounding that anyone would believe a government agency would ever offer such a service.
This incident serves as a stark reminder that even the most intelligent individuals can fall prey to outrageous scams. It highlights the urgent need for continued public education on scammers’ ever-evolving tactics, as many remain blissfully unaware of the dangers lurking in their midst.
In Singapore, the alarming trend of scams continued unabated in 2023, with a staggering 46,000 cases reported. This grim statistic has only intensified, with the first half of 2024 already witnessing an unprecedented high of 26,587 incidents. Clearly, there appears to be no respite from this troubling reality.
One might ponder why such easily avoidable scams continue to ensnare countless victims. A significant factor seems to be the diminishing interest in news and vital government communications. Many individuals have turned their backs on informative content in favour of the allure of entertainment found on social media platforms, leaving them vulnerable to deception.
This raises an unsettling question: How can it be that even seemingly well-educated people fall prey to these age-old schemes despite the plethora of warnings issued by authorities on numerous occasions?
Take, for example, the notorious investigation scams that have made headlines time and again. These scams often feature a familiar tactic: a so-called “foreign official” calling unsuspecting victims in Singapore. However, anyone aware of the facts would recognize that no legitimate overseas agency has the authority to conduct investigations in another country by simply placing a phone call.
Furthermore, the Singapore Police have consistently reiterated that they do not conduct police business over the phone or via social media channels. It is crucial to remember that the police will never contact you to verify personal information or banking details—let alone request that you transfer money.
To underscore the importance of vigilance, the Financial Industry Disputes Resolution Centre (Fidrec) has highlighted two alarming cases in its 2024 annual report. These cases serve as stark reminders that the best defence against scams is prevention.
Consider the case of a retiree who fell victim to a cunning fraudster. One day, she received an unexpected phone call from someone claiming to be a police officer from Beijing. The impersonator informed her that her credit card had been misused in China and threatened her with arrest if she didn’t comply with his demands.
Overwhelmed by fear at the thought of being arrested, the woman desperately sought a way to prove her innocence. The scammer then told her that he would connect her with “the Singapore Police Force” for further assistance. To heighten her anxiety, he insisted she keep their conversation confidential, warning her that her “life would be in danger” if the criminals behind the scam discovered her communication with him.
This troubling narrative serves as a sobering reminder of how easily trust can be exploited and how crucial it is for individuals to remain informed and sceptical. In an age where information is at our fingertips, neglecting to stay updated can lead to dire consequences.
Rather than questioning the situation, she complied with the second scammer’s directive to move her funds into a “safety account” established at one of her banks. The scammer subsequently provided her with a digital document featuring the bank’s letterhead, her account number, and her name as the account holder.
As a result, she executed multiple transfers amounting to $200,000 from her own account to this so-called “safety account.” Throughout this process, she failed to inquire about the necessity of these actions or how an account could be considered hers without her signature. She also neglected to consult her bank regarding the alleged unauthorized use of her card.
The harsh reality began to sink in when, after a week of unanswered calls to the “police” regarding her funds, she shared her concerns with her daughter. Her daughter, familiar with similar incidents from news articles, quickly warned her that she might have fallen victim to a scam.
Seeking assistance, the retiree turned to her bank. When that proved fruitless, she escalated the matter by filing a claim with Fidrec.
During mediation, she acknowledged that she had acted under duress from the scammers and had transferred money online, believing it was going into her own account. However, the bank clarified that the transfers were made willingly and that its procedures were followed correctly.
Additionally, the bank had sent alerts asking if she comprehended the nature of the transactions, but she chose to continue regardless. Nonetheless, the bank expressed compassion for her situation and offered a goodwill compensation of $20,000, representing 10 per cent of her loss.
In another instance, a woman named Jenny fell victim to a fraudulent travel promotion. Despite widespread awareness of the dangers associated with downloading any “payment app” for social media deals—commonly used by hackers to compromise devices—Jenny clicked on an enticing travel package advertisement.
The scammer instructed her to download an app and make a minimum deposit of $5 to access the discounts. Trusting their guidance, Jenny logged into her digital banking platform to make the payment.
Unbeknownst to her, she had inadvertently installed malware on her phone that harvested her banking credentials, including saved login passwords. The scammer then exploited this information to access her bank account and siphon off her funds.
Fortunately, the bank’s security measures detected the suspicious activities and promptly froze her account. However, two transactions involving undisclosed amounts had already been completed before the freeze was enacted.
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