Global sanctions guide

  1. Does Singapore have a sanctions regime in place?

Yes. Singapore implements United Nations Security Council Resolutions (“UNSCR”), including sanctions. It also has its own autonomous sanctions regime under the Terrorism (Suppression of Financing) Act (“TSOFA”).

Under the United Nations Act (Cap. 339), the Minister is empowered to make regulations to implement UNSCR. These regulations will apply to non-financial institutions and individuals. They do not apply to any financial institution that are regulated by the Monetary Authority of Singapore (“MAS”).

Instead, the MAS issues its own regulations implementing the UNSCR sanctions in respect of financial institutions.

  1. Does Singapore implement UN sanctions?

Yes, they are implemented through the United Nations Act in respect of nonfinancial institutions and individuals, and, through the MAS Act, in respect of financial institutions.

  1. Does Singapore implement an autonomous sanctions regime?

Yes, Singapore also has a list of sanctioned terrorist/terrorist entities under the TSOFA separate from the UNSCR 1267/1989 Al-Qaida Sanctions list or the UNSCR 1988 Sanctions List.

  1. What is the nature of the sanctions regime in Singapore?

The sanctions regime in Singapore has a dual approach where the UNSCR are generally implemented through regulations made under the UN Act whilst regulations targeting financial institutions are implemented under the MAS Act.

In addition, the TSOFA gives effect to the International Convention for the Suppression of the Financing of Terrorism and for matters connected therewith.

  1. 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:

  1. Are there any other lists related to sanctions?

The MAS issues notices and guidelines to financial institutions on anti-money laundering and countering the financing of terrorism. A list of the notices and guidelines may be found at the following link:

  1. 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 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.

  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 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 offence 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 offences of dealing with sanctioned individuals or entities under the TSOFA.

  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
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
F: (+65) 6250 8663

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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Contributor law firm

Surresh S, Eversheds Harry Elias LLP, 21/F, Gloucester Tower The Landmark, 15 Queen’s Road Central, Hong Kong, Peoples Republic of China