SINGAPORE: The Monetary Authority of Singapore (MAS) has fined a Singaporean man S$336,000 for insider trading, the authority announced on Tuesday (Jun 4).

A civil penalty was imposed on Tham Wai Mun Raphael after he sold shares in Anhua Clean Energy (ACE), a company listed on the Alternative Investment Market of the London Stock Exchange, while in possession of non-public, price-sensitive information about the organisation, said MAS in a media release.

Tham, who was the non-executive vice chairman of ACE, has admitted to contravening the insider trading prohibition of the Securities and Futures Act, and has paid MAS the penalty without court action.


ACE develops and produces split solar-powered water heater systems, according to the London Stock Exchange. It has two operating subsidiaries based in Shandong province in eastern China. 

On Jun 16, 2015, ACE announced that it was considering a share placement at a substantial price discount to raise about £1.5 million (US$1.9 million). Following the announcement, the price of its shares fell by 45 per cent to close at 7.75 pence.

Three days later, the organisation announced that it had placed out 38 million shares, representing 30 per cent of the enlarged share capital, at 4.5 pence apiece – a 44 per cent discount from the previous day’s closing price. This caused ACE’s share price to fall by another 30 per cent.

Armed with “non-public and price-sensitive information” about the share placement, however, Tham used investment holding company Foxtrox Holdings to sell 569,745 ACE shares on Jun 12, 2015, said MAS.

This allowed both Foxtrox and Tham to avoid a loss of £76,203, said MAS.

Tham – who was based in Singapore at the time – had authority over Foxtrox’s trading account when the trades took place, it added.


The penalty imposed by MAS represents 2.5 times the losses Tham had avoided from the sale of his shares, MAS said.

“The civil penalty action against Mr Tham, a Singaporean who engaged in insider dealing of shares listed in the United Kingdom, reflects our commitment to pursue offenders who commit market misconduct, regardless of whether the securities are listed in Singapore or overseas,” said Ms Loo Siew Yee, MAS assistant managing director (policy, payments and financial crime).

The case was referred to the authority by the United Kingdom’s Financial Conduct Authority, which also provided assistance in the investigation.

Tham has also given MAS a voluntary undertaking not to be a company director or be involved in the management of a company for a period of two years with effect from Jun 5 this year.