The Ministry of Manpower of Singapore
("MOM") has been consistently
implementing a multi-pronged strategy to tighten the work pass
regime for foreigners, with the primary goals of fostering a strong
local workforce, ensuring foreign workers complement local talent,
and maintaining fair hiring practices.
However, there are companies which seek to profit by
circumventing the work pass framework, by hiring "phantom
workers", to artificially inflate the number of qualifying
local employees in their employ, allowing them to hire additional
foreign workers under S Passes or Work Permits who they would
otherwise not be able to hire.
This disrupts the local employment ecosystem, with local workers
losing out on employment opportunities. This article examines what
constitutes a phantom employee, the key legal touchpoints and
sentencing considerations, tax risks, sectoral patterns and
enforcement trends, individual liability, and how these issues
compare with practices
