Between July 2013 and December 2015, Tan, via Noble Consulting, helped four SMEs raise a total of $15.355 million from 145 members of the public.
She helped organised multiple seminars, participated in investment exhibitions, created and disseminated marketing materials to potential investors.
The Investment or Loan Agreements that the investors entered into with Noble’s client companies were found by the State Courts to be debentures, a form of securities.
According to the Singapore Police Force in 2020, the lenders were promised interest payments of 12% to 28% per annum.
Noble Consulting, which did not have a valid, relevant license, took a 15% cut.
When the client companies subsequently defaulted on their loans, over 100 lenders suffered losses totalling around $9.5 million.
On June 3 2020, Tan was convicted and sentenced to 8 months’ imprisonment.
Her appeal was dismissed on March 5 2021.
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“Persons dealing in securities and capital market products must take steps to ensure that they comply with the licensing requirements under the Securities and Futures Act,” says Loo Siew Yee, MAS’ assistant managing director (policy, payments and financial crime).
“MAS’ licensing regime protects members of the public by admitting only fit and proper persons, who must carry out regulated activities in accordance with business conduct and other requirements. MAS will take stern action against errant companies and individuals who conduct regulated activities without a licence,” adds Loo.