Singapore implements United Nations sanctions and has made one exception to its usual restraint. The articles collected here explain the United Nations Act 2001 and the regulations under it, the Russia measures of March 2022, the commercial reach of OFAC, screening practice, proliferation financing and the position of the lawyer. Export control and the trade side are not yet treated on this site.
The United Nations Act 2001 empowers the Minister to give effect to decisions of the Security Council. The regulations bind any person in Singapore and any citizen abroad, and they forbid dealing with designated persons or making funds available to them.
On 5 March 2022 Singapore announced sanctions against Russia, acting for the first time in decades without a Security Council mandate. MAS implemented the financial measures.
Singapore does not adopt United States, European Union or United Kingdom sanctions as such. Its financial institutions nevertheless comply with them where a transaction touches those systems, so a trader should plan for that from the start.
The sections on screening and on proliferation financing show what this means for a compliance programme. Their examples come from digital payment token services, and the method is general.
Start with Singapore's approach to sanctions, the Russia measures of March 2022 or OFAC and the commercial reality.
Sanctions and Export Controls: UN Measures, Russia and Secondary Sanctions
A trading hub lives on the freedom of goods, ships and payments to move. Sanctions exist to stop some of them. Read more Singapore · Trade Finance and RiskUnited Nations sanctions in Singapore law
Singapore follows the dualist tradition of the common law. Read more Singapore · Trade Finance and RiskSingapore’s measures against Russia since 2022
Russia invaded Ukraine on 24 February 2022. Read more Singapore · Trade Finance and RiskUnited States and European sanctions and their reach
The official position is clear. Read more Singapore · Trade Finance and RiskShip-to-ship transfers, dark fleets and maritime risk
Singapore is the largest bunkering port in the world and one of the main centres for the storage and blending of oil, as Chapters G.II and G.III describe. Read more Singapore · Trade Finance and RiskStrategic goods control
The control of military and dual-use goods is older than the measures against Russia. Read more Singapore · Trade Finance and RiskSanctions and Export Controls: UN Measures, Russia and Secondary Sanctions: practical consequences
For banks, the Singapore law of sanctions is relatively simple. The commercial pressure of foreign sanctions adds most of the complexity. Read more Singapore · Trade Finance and RiskSanctions and Export Controls: UN Measures, Russia and Secondary Sanctions: Comparison with Geneva, Hong Kong and Dubai
The contrast with Geneva is clear. Read more Singapore · Trade Finance and RiskSanctions and Export Controls: UN Measures, Russia and Secondary Sanctions: summary
Singapore implements UN Security Council sanctions through the United Nations Act 2001, MAS regulations and trade controls administered by Singapore Customs. Read more Singapore · AML and SanctionsSingapore's approach to sanctions
Singapore's sanctions policy differs from Switzerland's in a way that a dual-hub compliance programme must take into account from the first day. Read more Singapore · AML and SanctionsUnited Nations sanctions: the legal mechanism
The United Nations Act 2001 empowers the Minister to make regulations to give effect to decisions of the United Nations Security Council under Article 41 of the Charter. Read more Singapore · AML and SanctionsThe Russia measures of March 2022
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. Read more Singapore · AML and SanctionsOFAC and the commercial reality
No Singapore law requires a Singapore DPT licensee to comply with United States sanctions administered by the Office of Foreign Assets Control (OFAC). Read more Singapore · AML and SanctionsScreening practice for a DPT licensee
Sanctions screening at a DPT licensee has three components that a fiat institution's screening lacks or has in simpler form. Read more Singapore · AML and SanctionsProliferation financing
The FATF added a proliferation-financing risk-assessment requirement to Recommendation 1 in October 2020. Read more Singapore · AML and SanctionsSanctions and the lawyer
A lawyer advising a DPT licensee on sanctions in Singapore must hold three jurisdictions in view at once. The Singapore layer determines what is unlawful and what must be frozen and reported. Read more