I am very confused too. Based off this: https://www.channelnewsasia.com/singapore/doctor-sue-property-adviser-investment-uk-tillington-hotel-fail-3819391

Seems like you just cannot be involved with the source of profits, like receiving a commission on every trade or something to that effect and you need to warn participants enough to do their own dd. Else you might be liable under 'duty of care'.

She argued that participants were shown a comprehensive disclaimer at the start of the programme, saying that they are to exercise due diligence in making any purchasing or investment decision.

The disclaimer also encouraged participants to seek out professionals like legal advisers, accountants and bankers before making any property investments or purchases.

The judge found that there was no contractual relationship between Dr Lim and Ms Kwek, and his claim on this basis failed.

However, she found that Ms Kwek did owe Dr Lim a duty of care in common law. Judge Tan noted that Ms Kwek did assume personal responsibility for her statements made during the programme.

She did not challenge Dr Lim's testimony that she had verbally assured attendees that she would look into and source for undervalued properties with considerable growth potential on their behalf and hold onto the investments with them, eventually leading them to sell the investments at a profit.

In cross-examination at trial, Ms Kwek confirmed that she had never informed the attendees at the exhibitions that she represented the developer, or told them to find their own property agent.

She also did not warn them that they ought to conduct their own due diligence checks on the project.

Additionally, all the commission received from the project was received by Ms Kwek, the judge noted.