Singapore

Global sanctions guide

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  1. Does Singapore have a sanctions regime in place?

Yes.

  1. Does Singapore implement UN sanctions?

Yes. Under the United Nations Act (Cap. 339) (“the Act”), the Minister is empowered to make regulations to implement UN Security Council resolutions. However, the Act does not apply to any financial institution that is subject to the directions of the Monetary Authority of Singapore.

  1. Does Singapore implement an autonomous sanctions regime?

Yes. Under the Monetary Authority of Singapore Act (Cap. 186), the Monetary Authority may issue directions or regulations to financial institutions to comply with UN Security Council resolutions, prevent money laundering or prevent the financing of terrorism. As well, the Terrorism (Suppression of Financing) Act (Cap. 325) sets out prohibitions against facilitating any terrorist act and dealing with the property of terrorists, and identifies a list of sanctioned individuals and entities.

  1. Does Singapore implement an autonomous sanctions regime?

Singapore has enacted legislation to give effect to various UN Security Council resolutions. For example, the United Nations Act gives effect to resolutions through regulations established pursuant to the Act. The Monetary Authority of Singapore also gives effect to targeted financial sanctions through regulations issued pursuant to the Monetary Authority of Singapore Act.

Additionally, legislation such as the Terrorism (Suppression of Financing) Act gives effect to the International Convention for the Suppression of the Financing of Terrorism and connected matters.

  1. Does Singapore maintain a list of sanctioned individuals and entities?

Yes. The list of designated individuals and entities which are sanctioned pursuant to the Monetary Authority of Singapore Act, the United Nations Act and the Terrorism (Suppression of Financing) Act is maintained by the Monetary Authority of Singapore and may be found here.

  1. Are there any other lists related to sanctions?

Yes. The Monetary Authority of Singapore also issues notices to financial institutions on anti-money laundering and countering the financing of terrorism.  A list of the notices and guidelines may be found here.

  1. Does Singapore have a licensing or authorisation system in place?

Yes. Exemptions may be granted in certain cases. For example, under the Terrorism (Suppression of Financing) Act, the Minister may exempt any person in Singapore, or any citizen outside Singapore, in respect of any specified activity or transaction that would otherwise contravene the Act. Similarly, under the United Nations (Sanctions – Iran) Regulations 2014, the Minister may, if he considers it appropriate in the circumstances and consistent with the intention of the relevant UN Security Council resolutions, exempt any person or class of persons or any activity or class of activities from any or all of the provisions of those Regulations.

  1. What are the consequences for a breach of sanctions in Singapore?

The consequences vary depending on the relevant legislation or provision that has been breached. For instance, a financial institution which fails to comply with any of the Monetary Authority of Singapore Regulations may be guilty of an offence and liable to a fine up to SGD 1,000,000.

Under the Act, every person who commits, attempts to do so, does any act with intent to commit, or aids, abets or conspires with another person to commit an offence may be liable to a fine of up to SGD 1,000,000 and/or imprisonment for up to 10 years. Similar penalties apply in respect of offences under the Terrorism (Suppression of Financing) Act.

  1. Who are the relevant regulators in Singapore and what are their contact details?

The Monetary Authority of Singapore is responsible for financial sanctions

Monetary Authority of Singapore,
10 Shenton Way, MAS Building,
Singapore, 079117

T: (+65) 6225 5577
E: webmaster@mas.gov.sg
F: (+65) 6229 9229

Singapore Customs is responsible for sanctions on trade in strategic goods and strategic goods technology.

Singapore Customs,
55 Newton Road #10-01,
Revenue House, Singapore, 307987

T: (+65) 6355 2000
E: customs_stgc@customs.gov.sg
F: (+65) 6250 8663

The Inter-Ministerial Committee on Terrorist Designation is responsible for matters relating to the designation of terrorists.

IMCTD, c/o Ministry of Home Affairs,
New Phoenix Park, 28 Irrawaddy Road,
Singapore, 329560

T: (+65) 6478 7010
F: (+65) 6254 6250

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