1. Does Singapore have a sanctions regime in place?
2. Does Singapore implement UN sanctions?
Yes. As a member state of the UN, Singapore implements UN sanctions through the United Nations Act (Cap. 339) (UNA), UNA which applies to non-financial institutions and individuals, and, through regulations issued by the Monetary Authority of Singapore (MAS) under the MAS Act, which apply to financial institutions
3. Does Singapore implement an autonomous sanctions regime?
Singapore also applies targeted financial sanctions against designated individuals and entities under the Terrorism (Suppression of Financing) Act (TSOFA), The relevant individuals and entities are designated by the Inter-Ministry Committee on Terrorist Designation pursuant to the United Nations Security Council (UNSC) Resolution 1373 relating to terrorism. Variable Capital Companies are required to comply with targeted financial sanctions issued under the Variable Capital Companies Act.
4. What is the nature of the sanctions regime in Singapore ?
As noted above, the sanctions regime in Singapore has a dual approach where the UNSCR are generally implemented through regulations made under the UN Act, while regulations targeting financial institutions are implemented under the MAS Act.
In addition, TSOFA gives effect to the International Convention for the Suppression of the Financing of Terrorism.
5. Does Singapore maintain a list of sanctioned individuals and entities?
Singapore does not have a consolidated searchable list of sanctioned individuals and entities. The MAS does maintain a website with links to the relevant UN lists as well as the schedule of terrorist/ terrorist entities under the TSOFA here.
6. Are there any other lists related to sanctions?
The MAS issues regulations and notices to financial institutions on anti-money laundering and counter-terrorist financing measures. A list of the notices and guidelines may be found here.
7. Does Singapore have a licensing or authorization system in place?
Exemptions may be granted in appropriate cases by either the Minister of Home Affairs or the MAS. By way of example, under TSOFA, 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.
8. 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 offense and liable to a fine up to Singapore Dollars (SGD) 1 million.
Under the United Nations 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 offense may be liable to a fine of up to SGD 1 million or to imprisonment for a term up to 10 years or to both. Similar penalties apply in respect of offenses of dealing with sanctioned individuals or entities under the TSOFA.
9. Who are the relevant regulators in Singapore and what are their contact details?
The Monetary Authority of Singapore is responsible for enforcing financial sanctions.
Monetary Authority of Singapore
10 Shenton Way, MAS Building, Singapore, 079117 T: (+65) 6225 5577 F: (+65) 6229 9229 E: firstname.lastname@example.org
Singapore Customs is responsible for enforcing trade sanctions.
c/o Ministry of Home Affairs, 55 Newton Road #10-01, Revenue House, Singapore, 307987
T: (+65) 6355 2000 F: (+65) 6250 8663 E: email@example.com
The Inter-Ministerial Committee on Terrorist Designation is responsible for matters relating to the designation of terrorists.
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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