The Russia measures of March 2022

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On 5 March 2022 Singapore announced sanctions against Russia in response to the invasion of Ukraine, acting for the first time in decades without a Security Council mandate. The Ministry of Foreign Affairs explained the departure from practice by reference to the unprovoked invasion of a sovereign state and the paralysis of the Security Council by the Russian veto.¹ The financial measures implemented by MAS prohibited financial institutions from dealing with four named Russian banks (VTB, VEB.RF, Promsvyazbank and Bank Rossiya). They also prohibited participation in the issuance of or dealing in new securities and financing of designated Russian government-linked entities. Finally, they prohibited financial services that would facilitate fund-raising by the Russian government or central bank.

Most relevant here, the measures included an express prohibition on DPT transactions. MAS directed financial institutions, including DPT service providers, to refrain from facilitating transactions involving DPTs that could be used to circumvent the other measures. In practice this meant blocking transactions connected to the designated banks and entities and treating Russian-nexus DPT flows as higher-risk.² The DPT prohibition was unusual at the time and showed that MAS regarded crypto as a circumvention channel from the start of the Russia measures. The export-control side, administered by Singapore Customs under the Strategic Goods (Control) Act 2002, restricted military and dual-use goods and certain electronics.

The Singapore measures were narrower than the EU, United Kingdom or United States packages. Singapore did not freeze the assets of oligarchs, did not impose a general ban on crypto services to Russian residents as the EU did in October 2022, and did not adopt the oil price cap. A Russian national resident in Singapore who is not connected to a designated entity may lawfully hold a DPT account at a Singapore licensee, subject to enhanced due diligence. The same person could not be served from the licensee's Swiss affiliate if the Swiss ordinance's crypto-services prohibition applied to them (see Part F, Chapter VII). The asymmetry is one of the clearest examples of why a dual-hub group cannot run a single customer-acceptance policy without a jurisdiction-specific layer.

Notes

Ministry of Foreign Affairs, Singapore, statement of 28 February 2022 and press release of 5 March 2022 announcing sanctions and restrictions against Russia; MAS, media release of 5 March 2022, "MAS Imposes Financial Measures Against Russia". ↩
MAS, media release of 5 March 2022, and the accompanying MAS notice to financial institutions on financial measures in relation to Russia, including the prohibition on facilitating transactions in digital payment tokens that could circumvent the measures. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

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SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

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