Overview
Singapore is a UN member state and implements UN sanctions via the United Nations Act 2001.
Singapore does not have general autonomous sanctions legislation, however it has imposed sanctions in response to Russia’s invasion of Ukraine consisting of an export ban and asset freezing pursuant to Notice SNR-N01 Financial Measures in Relation to Russia, Notice SNR-N02 Financial Measures in Relation to Russia – Non-prohibited Payments and Transactions and the Strategic Goods (Control) Order 2021.
Singapore adopts sanctions against designated individuals and entities suspected of terrorism under the Terrorism (Suppression of Financing) Act 2002.
The Monetary Authority of Singapore gives effect to UN and autonomous sanctions through regime-specific Financial Services and Markets Regulations, which generally require financial institutions to:
- immediately freeze funds, other financial assets or economic resources of designated individuals and entities;
- not enter into financial transactions or provide financial assistance or services in relation to designated individuals, entities or items, or proliferation, nuclear or other sanctioned activities; and
- inform MAS of any fact or information relating to the funds, other financial assets or economic resources owned or controlled, directly or indirectly, by a designated individual or entity.
Non-financial institutions and individuals in Singapore are also required to comply with sanctions requirements in relation to designated individuals and entities.
National Competent Authorities
The Monetary Authority of Singapore is responsible for sanctions. The Ministry of Home Affairs and the Ministry of Foreign Affairs have the authority to designate individuals and entities as terrorists.
Singapore Customs manages import/export controls.
Legislation
The Monetary Authority of Singapore gives effect to UN sanctions through the Financial Services and Markets Regulations issued pursuant to section 192, read with sections 15(1)(b) and 219(d), of the Financial Services and Markets Act 2022 and the Variable Capital Companies (Sanctions and Freezing of Assets of Persons) Regulations 2020 issued pursuant to section 83(1)(b) of the Variable Capital Companies Act 2018 . The FSM Regulations and the VCC Regulations apply respectively to all financial institutions and variable capital companies in Singapore.
Notice SNR-N01 Financial Measures in Relation to Russia
Notice SNR-N02 Financial Measures in Relation to Russia – Non-prohibited Payments and Transactions
Strategic Goods (Control) Act 2002
Strategic Goods (Control) Order 2021
Terrorism (Suppression of Financing) Act 2002
Regulations
DPRK
Variable Capital Companies (Sanctions and Freezing of Assets of Persons) Regulations 2020
United Nations (Sanctions – Democratic People’s Republic of Korea) Regulations 2010
Democratic Republic of the Congo
Variable Capital Companies (Sanctions and Freezing of Assets of Persons) Regulations 2020
United Nations (Freezing of Assets of Persons – Democratic Republic of Congo) Regulations 2006
Iran
Financial Services and Markets (Sanctions and Freezing of Assets of Persons — Iran) Regulations 2023
Variable Capital Companies (Sanctions and Freezing of Assets of Persons) Regulations 2020
United Nations (Sanctions – Iran) Regulations 2019
Libya
Variable Capital Companies (Sanctions and Freezing of Assets of Persons) Regulations 2020
Somalia
Variable Capital Companies (Sanctions and Freezing of Assets of Persons) Regulations 2020
South Sudan
Financial Services and Markets (Freezing of Assets of Persons — South Sudan) Regulations 2023
Variable Capital Companies (Sanctions and Freezing of Assets of Persons) Regulations 2020
United Nations (Sanctions – South Sudan) Regulations 2019
Sudan
Financial Services and Markets (Freezing of Assets of Persons — Sudan) Regulations 2023
Variable Capital Companies (Sanctions and Freezing of Assets of Persons) Regulations 2020
United Nations (Freezing of Assets of Persons – Sudan) Regulations 2006
Yemen
Financial Services and Markets (Freezing of Assets of Persons — Yemen) Regulations 2023
Variable Capital Companies (Sanctions and Freezing of Assets of Persons) Regulations 2020
United Nations (Sanctions – Yemen) Regulations 2015
4 Oct 2022
Counter-Terrorism
Terrorism (Suppression of Financing) Act
United Nations (Anti-Terrorism Measures) Regulations
ISIL (Da’esh) and Al-Qaida List
All other persons identified in the First Schedule of the Terrorism (Suppression of Financing) Act
25 Apr 2024
30 Jan 2019
5 Oct 2021
Guidance
Monetary Authority of Singapore – Targeted Financial Sanctions
Ministry of Home Affairs: Countering the Financing of Terrorism
Licensing
Financial Measures In Relation To Russia – Non-Prohibited Payments And Transactions – this Notice sets out categories of payments and transactions which are excluded from the prohibition on dealing with certain designated Russian banks (in Notice SNR-N01).
Non-prohibited payments include payments for basic expenses, transactions involving a designated bank to facilitate withdrawal of a person’s funds from a non-designated bank, and transactions necessary for the performance of the functions of the Russian Embassy in Singapore.
Enforcement
Under the Financial Services and Markets Act 2022, a financial institution that contravenes any FSM Regulations may be subject to a fine not exceeding $1 million.
Under the UN Act 2001, an individual who commits an offence under any Regulations made under the UN Act may be liable to a fine not exceeding $500,000 or to imprisonment for a term not exceeding 10 years or to both and an entity may be liable to a fine of up to $1 million.
De-listing
Singapore citizens and Singapore-incorporated entities who are designated by the UN may request that the Singapore Ministry of Foreign Affairs (webmaster@mas.gov.sg) submit a de-listing request on their behalf to the relevant UN Sanctions Committee.
Judgments
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Kuvera Resources Pte Ltd v JPMorgan Chase Bank NA [2023] SGCA 28
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The “Sahand” and other applications [2011] SGHC 27
