What offence did Galvez Mary Joe Blanco plead guilty to and what sentence was imposed at first instance?

Galvez Mary Joe Blanco pleaded guilty to a charge under s 55A(1)(a)(i) read with s 55A(1)(b)(iii) of the CDSA for an arrangement involving another person's criminal proceeds between 15 and 29 May 2024. The District Judge sentenced her to 40 days' imprisonment; she appealed to the High Court in [2026] SGHC 110.

[2026] SGHC 110 — GALVEZ MARY JOE BLANCO v PUBLIC PROSECUTOR

SUPREME COURT OF SINGAPORE

21 May 2026

Case summary

Galvez Mary Joe Blanco v Public Prosecutor [2026] SGHC 110

Magistrate’s Appeal No 9080 of 2025

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Decision of the General Division of the High Court (comprising Sundaresh Menon CJ, Tay Yong Kwang JCA and See Kee Oon JAD)

(judgment delivered by Tay Yong Kwang JCA):

Outcome: The General Division of the High Court set out a sentencing framework for a scams-related offence. The Court held that the District Court was correct in not calling for a probation suitability report and dismissed the appellant’s appeal against the sentence of 40 days’ imprisonment.

Pertinent and significant points of the judgment

• The Sentencing Advisory Panel’s Guidelines for Scams-Related Offences (“”Scam Offences Guidelines”) are not directly relevant since offences under s 55A(1)(a)(i) read with s 55(1)(b)(iii) of the Corruption, Drug Trafficking and other Serious Crimes (Confiscation of Benefits) Act 1992 (2020 Rev Ed) (“CDSA”), punishable under s 55A(5) of the CDSA (“s 55A(1)(b)(iii) Offences”) do not involve the handing over of control of a bank account. Nonetheless, the policy considerations discussed in the Scam Offences Guidelines in relation to scams-related offences are useful for the court in the present case: at [30].

• Deterrence and retribution are the dominant sentencing considerations for scams-related offences, including s 55A(1)(b)(iii) Offences, because of their devastating effects, prevalence and continued proliferation locally and worldwide: at [39].

• Probation is inappropriate as a sentencing option for scams-related offences, such as s 55A(1)(b)(iii) Offences. This applies regardless of whether the offender is a foreigner, a Singapore citizen or permanent resident. Granting probation to a foreign offender working in Singapore would be extremely rare because immigration and employment policies would often render such an order impracticable: at [41]–[42].

• The framework set out in Logachev Vladislav v Public Prosecutor [2018] 4 SLR 609 (“Logachev”) is appropriate for s 55A(1)(b)(iii) Offences. The offending conduct in s 55A(1)(b)(iii) Offences may occur in many different ways in a wide variety of situations. The versatility of a Logachev framework is useful in addressing the diversity of such offending conduct: at [46].

• It is an aggravating factor to facilitate the laundering of criminal proceeds as such crimes tend to undermine public confidence in financial institutions and payment accounts in general and the almost ubiquitous bank accounts in particular: at [50].

• The vulnerability of victims should be regarded as an aggravating factor. Where vulnerable victims are involved, usually those who are elderly, the consequences of scams-related offences are often much graver, both in terms of the financial losses and the resultant psychological damage caused to the vulnerable victims and their families: at [51].

Background

1 This was an appeal against the decision of a District Judge (“DJ”) to sentence the appellant to 40 days’ imprisonment after she pleaded guilty to a s 55A(1)(b)(iii) Offence.

2 The appellant was a foreign domestic worker from the Philippines. At the material time, she was working in the same household as another foreign domestic worker, Maria Luz Suerte Lopez (“Maria”).

3 Sometime in May 2024, Maria received a friend request on the TikTok application from a person known as Alex Stillinger (“Alex”). About two weeks later, Alex requested Maria’s help to receive moneys that he had allegedly earned through his investments in gold. After Maria agreed to help Alex, she solicited the appellant’s assistance to receive moneys into the appellant’s POSB bank account as Maria did not have a bank account at that time.

4 Between 15 May 2024 and 29 May 2024, in Singapore, a total of $118,133 was transferred by Alex into the appellant’s POSB bank account. The appellant then transferred $116,154.51 to a Thai bank account. At all material times, the appellant failed to take reasonable steps to ascertain the destination of the money. Out of this amount, $20,300 was traceable directly to the losses suffered by two scam victims, a 61-year-old female sales adviser and a 70-year-old female kitchen helper.

Decision

Some preliminary issues

5 The Scam Offences Guidelines are not directly relevant since s 55A(1)(b)(iii) Offences do not involve the handing over of control of a bank account. Nonetheless, the policy considerations discussed in the Scam Offences Guidelines in relation to scams-related offences are useful for the court in the present case: at [30].

6 It is unnecessary to determine whether s 55A(1)(b)(iii) Offences are strict liability offences because nothing turns on such a classification in this appeal: at [31]-[34].

7 There is no need to differentiate bank accounts from other types of payment accounts for the purposes of developing a sentencing framework for s 55A(1)(b)(iii) Offences: at [35]-[36].

Whether the DJ should have called for a probation suitability report

8 The recommendations of the Scam Offences Guidelines that custodial sentences be the norm for scams-related offences and that fines, probation and community sentences are generally not appropriate are equally applicable in the present case although the appellant was not the scammer. Deterrence and retribution are the dominant sentencing considerations for scams-related offences, including s 55A(1)(b)(iii) Offences, because of their devastating effects, prevalence and continued proliferation locally and worldwide: at [37]–[39].

9 Probation is generally inappropriate as a sentencing option for scams-related offences such as s 55A(1)(b)(iii) Offences. Even if an adult offender demonstrates an extremely strong propensity for reform, deterrence and retribution will still displace rehabilitation as the dominant sentencing considerations because of the serious nature of s 55A(1)(b)(iii) Offences. This is true regardless of whether the offender is a foreigner, a Singapore citizen or permanent resident. Granting probation to a foreign offender working in Singapore would be extremely rare because immigration and employment policies would often render such an order impracticable: at [41]–[42].

10 Since deterrence and retribution are the dominant sentencing considerations for the offence at issue, probation is not a suitable sentencing option and the DJ was correct in deciding not to call for a probation suitability report: at [43].

What is the appropriate sentencing framework for s 55A(1)(b)(iii) Offences

11 A distinction should not be drawn between “Money Mules” and “Victim Mules”. It would not be appropriate to have a clear dichotomy between “Money Mules” and “Victim Mules” when most cases would have characteristics of both the described categories. In any case, the structure of Part 6 of the CDSA already recognises varying degrees of culpability of offenders who commit scams-related offences: at [44]–[45].

12 A Logachev framework is appropriate for s 55A(1)(b)(iii) Offences. The offending conduct of s 55A(1)(b)(iii) Offences may occur in many different ways in a wide variety of situations. The versatility of a Logachev framework is useful in addressing the diversity of such offending conduct: at [46].

13 The sentencing matrix set out by the court utilises the full range of punishments provided. It creates an even escalation of the indicative sentencing ranges by using multiples of six months’ imprisonment for each tier of harm and culpability. If the sentencing court deems it fit that a fine should be imposed for the disgorgement of criminal benefits in addition to imprisonment, it can do so: at [47].

14 For s 55A(1)(b)(iii) Offences, the offence-specific factors identified in Huang Ying-Chun v Public Prosecutor [2019] 3 SLR 606 (“Huang Ying-Chun”) at [98] are a useful starting point but have to be modified to take into account the nature of s 55A(1)(b)(iii) Offences: at [48].

15 If the Prosecution wishes to rely on the fact that the predicate offence harmed confidence in Singapore’s public administration as an aggravating factor for s 55A(1)(b)(iii) Offences, it will have to show some nexus between the offender and the predicate offence by way of the offender’s knowledge or reasonable grounds of belief. In any case, the Prosecution can simply rely on the aggravating factor that facilitating the laundering of criminal proceeds tends to undermine public confidence in financial institutions and payment accounts in general and the almost ubiquitous bank accounts in particular: at [49]–[50].

16 The vulnerability of victims should be regarded as an aggravating factor. Where vulnerable victims are involved, usually those who are elderly, the consequences of scams-related offences are often much graver, both in terms of the financial losses and the resultant psychological damage caused to the vulnerable victims and their families: at [51]-[56].

17 The factor of “the amount cheated” in the Huang Ying-Chun framework should be revised to “the amount laundered” as it reflects more accurately the nature and the scope of s 55A(1)(b)(iii) Offences. Where significant funds of $100,000 or more were received or transferred out of the offender’s bank account, there should be an uplift in sentence: at [57]–[58].

18 The number and the frequency of transactions are relevant considerations and can be assimilated into the factor of the “duration of offending” in the Huang Ying-Chun framework by broadening it to the “duration, number and frequency of offending”: at [59].

Whether the DJ’s sentence of 40 days’ imprisonment is manifestly excessive

19 In this case, the harm was in the moderate category and the culpability was in the low category. The indicative sentence would be in the sentencing range of six to twelve months’ imprisonment. The DJ did not appear to have taken into account the fact that at least one vulnerable victim was impacted in this case. Taking into account this additional offence-specific factor, the appropriate starting point in the sentencing range should be seven months’ imprisonment. The starting point could be adjusted downwards by one month to account for the mitigating factors. Applying a further 30% reduction for the appellant’s early plea of guilt, the final sentence would be slightly more than four months’ imprisonment: at [61]–[64].

20 There is therefore no merit in the appellant’s contentions that her sentence of 40 days’ imprisonment was manifestly excessive. Accordingly, the Court dismissed her appeal against sentence.: at [65].

This summary is provided to assist in the understanding of the Court’s grounds of decision. It is not intended to be a substitute for the reasons of the Court. All numbers in bold font and square brackets refer to the corresponding paragraph numbers in the Court’s grounds of decision.

GALVEZ MARY JOE BLANCO v PUBLIC PROSECUTOR

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What offence did Galvez Mary Joe Blanco plead guilty to and what sentence was imposed at first instance?

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