Like so many migrant workers coming to TWC2 for help, Domog (name changed) has a multi-layered story. “My employer pushing me pay for house and pay for levy,” he says.

One minute later, he highlights another angle of the story. “Boss say stop work. He threat me – he want to cancel my permit.”

Another minute later, after telling us about going to see a doctor in the first week of June about metal grit in his eye, “My agent call me and say, ‘You no go doctor, no MC take.'” It was a warning against seeking medical treatment and getting medical leave.

Domog’s situation is hardly untypical. Migrant workers try to be as stoic as possible; it is only when their problems become a tangled knot of multiple issues that they finally look for help. It also makes it difficult for this writer to profile cases like his. With so many subplots, how do we tell his story in a comprehensible way?

I choose a part of his story that has not often been covered: illegal agent fees. This is actually shockingly common with most workers reporting similar money demands. Yet, perhaps because remedies may be easier to obtain for salary arrears or injury compensation, much of TWC2’s casework tend not to focus on agent fees, and so we may not cover this issue as much in our stories.

That said, getting the facts out of Domog requires the patience of Job. He keeps going off-topic, veering into numerous more pressing issues while scrolling through his phone looking for screenshots of payment transfers to his agent.

“Then he say want to reduce my salary,” Domog mumbles.

“Who? Your agent?” we ask.

“No, my boss.”

“Leave that for later. Concentrate on my question. Find the bank transfer you told me about.”

“Then yesterday, he say I must pay house money,” Domog adds.

“Concentrate, please.”

The agents

It turns out that there were two individuals involved in getting this job for him. They seemed to be working as a pair. The man was the one Domog communicated with more often, but he also knew the name of the woman. We believe these two were associated with the employment agency stated on Domog’s documents (though we’re not absolutely sure) because the name by which Domog refers to the male agent (“R**”) is similar to the name of the “key personnel” shown on a page at the Ministry of Manpower’s website in relation to this employment agency. As for the woman’s name , we can’t see it anywhere in the list of licensed agents.

Domog got this job with an airconditioning company rather recently, in April 2025. He didn’t come into this job from Bangladesh; instead he transferred into it from another job in Singapore. The significance of this context is that everything we are going to describe about agents and payments took place in Singapore. In short: within Singapore jurisdiction.

We see that the In-Principle Approval – a document issued by the Ministry of Manpower (MOM) confirming that a Work Permit would be available for him at the airconditioning company – was dated 17 April 2025 . Besides carrying the name of a licensed employment agency involved in the recruitment, it also showed how much the agency declared to MOM as the fee they charged – $600.

“How much did you actually pay?” we ask. At TWC2, we know only too well that in most workers’ cases that we see, the officially-declared fee amounts are false.

“$1,500,” Domog replies without hesitation.

It wasn’t paid in one go, but in at least five transfers, a few hundred dollars at a time. “I borrow something, I pay. Then another friend I borrow, and I pay again.”

He is able to show us four transactions totalling $1,200.

“What about the balance of $300?” we ask.

“That I pay before, and the picture I have but in my old phone.”

We look carefully at the details of the four transfers that have been recorded on his current phone. Making up $1,200 together, that’s already twice what was declared to MOM and shown on the IPA.

  • The earliest on this phone was dated 17 April 2025. A sum of $100 was paid to POSB Bank account number ***-**107-7. The date is significant, Domog points out. “That day, the IPA approve, and the agent say must pay immediate.” The implied consequence of not paying was that the IPA would be cancelled.
  • The second and third transactions on his phone were dated 21 April 2025, with $200 sent to POSB account number ***-**895-7, followed by another $500 to the same account.
  • The fourth transaction he shows us seem to be dated 23 April 2025 (not entirely clear). It was for $400 sent to the POSB account of a certain “Sami” with account number ***-**259-4.

It’s interesting how Domog was asked to transfer money into several different accounts, all in Singapore. We know from Domog that he was in contact with two individuals during the recruiting process, but there may be more people profitting from the payments.

“How did you know these account numbers?” we ask. “Did you keep the WhatsApp messages where your agents provided you with these account numbers?”

“Talking give,” replies Domog. Interesting again. The agents were careful not to leave a written record of their demands. Instead they spoke to him on the phone when providing the details. This lack of a documented nexus between agent(s) and account numbers is hardly unusual, and it is what makes proving any accusation of illicit agency fees difficult. However, if we are serious about stopping this cancer of illegal agent fees, there are other ways to go about it. Singapore just doesn’t seem to want to try.

Follow the money

If a worker, such as Domog, provides a list of transactions that are allegedly for agency services, questions can then be asked of the account-holders as to the reason for such incoming funds. The transactions would also show the worker (Domog in this case) as the transferor, and the recipients can be asked what their relationships were with the transferor that justified such payments.

Recipients should be investigated for income tax evasion if they had not declared such income, and if they are found to have been receiving such money for agent activities, they should face consequences (a) for illegally acting as agents if they were not licensed, or (b) for false declaration to MOM if the amounts they received differ from the amounts declared in the In-Principle Approval.

The Employment Agencies Act provides enough teeth. It is enforcement that is mysteriously elusive.

Large scale

Domog’s is not an isolated case. About half, if not more, of clients coming to TWC2 report that the agents whom they used (and paid) operated out of Singapore. Typically, they are not licensed either. How numerous are they? We can do a back-of-the-envelope calculation.

Just considering migrant workers in construction and related trades, published data shows there were 456,800 of them in December 2024. Since we know from earlier surveys conducted by TWC2 that they typically change jobs once every four years or so, that means about 114,000 of them change jobs each year. If they pay an average of $2,500 each to get a new job – an average estimated from the thousands of repeat workers we’ve seen over recent years – and half of them pay to someone in Singapore, then that makes $140 million in likely-illicit transactions annually. Within Singapore.

(Repeat workers are those entering their second or subsequent jobs in Singapore. We speak only of repeat workers here because first-time workers almost never use agents operating from Singapore)

$140 million annually is a lot of dirty money sloshing around. Does the tax man get any bite of this? Does the tax man even check? Or has all the money been successfully laundered to look clean?

Singapore prides itself as a financial centre. From the perspective of migrant workers and even the most cursory glance at agent fees and payment channels, one has to wonder about the dirty washing beneath the hype.

See also: Honeypot for illegal agents

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