Policy on Anti-Money Laundering and Countering the Financing of Terrorism

Singapore adopts a whole-of-government approach to combating money laundering (ML) and terrorism financing (TF).

The effort is led by the Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Steering Committee, comprising the Permanent Secretary of the Ministry of Home Affairs, Second Permanent Secretary of the Ministry of Finance and Managing Director of the Monetary Authority of Singapore.

Singapore's AML/CFT Policy Objectives are to:

• Detect, deter and prevent ML, associated predicate offences and TF
• Protect the integrity of its financial system from illegal activities and illicit fund flows.

The AML/CFT Efforts are Centred on:

• Having a sound and comprehensive legal, institutional, policy and supervisory framework
• Low crime rate
  
• Intolerance for corruption
  
• An efficient judiciary
  
• Close international cooperation with other jurisdictions
  
• An established culture of compliance
  
• Effective monitoring of the measures implemented
  
• Decisive law enforcement actions against ML/TF threats

To Achieve the Policy Objectives, Singapore Follows these Principles:

• Allocate law enforcement, financial intelligence and supervisory resources on a risk-sensitive basis
• Maintain close policy and operational coordination and cooperation across the Government
• Take a preventive approach that combines tough licensing and comprehensive reporting requirements, strict AML/CFT regulations, and risk-based supervision of the relevant financial and non-financial sectors
• Enhance private sector stakeholders' understanding of ML/TF risks and promote a culture of compliance
• Take decisive and deterrent law enforcement action against ML/TF activity, including that relating to foreign crimes
  
• Disrupt drug dealing and other serious offences early to prevent proceeds from being laundered
  
• Provide assistance to other jurisdictions through formal and informal channels spontaneously and on request
  
• Rigorously implement and contribute to the development of international standards, including the international standards on combating money laundering and the financing of terrorism and proliferation set by the Financial Action Task Force and United Nations Security Council Resolutions (particularly for targeted financial sanctions related to terrorism and proliferation of weapons of mass destruction)

Environmental Crime Money Laundering (“Env Crime ML”) National Risk Assessment (“NRA”):

Singapore’s Environmental Crime Money Laundering (ML) National Risk Assessment (NRA) provides a targeted overview of Singapore’s environmental crime ML risk environment and identifies the key threats and vulnerabilities Singapore is exposed to. It also outlines relevant mitigation measures that government agencies and private sector can develop and implement to address ML risks arising from environmental crimes.

• Environmental Crime Money Laundering National Risk Assessment (PDF, 460 KB)

The Environmental Crime ML NRA assessed that Singapore’s key exposure to environmental crimes ML stems from our position as an international financial center, and a trading and transit hub, with a highly externally-oriented economy. Singapore is susceptible to threats that emanate from illegal wildlife trafficking, illegal logging, and waste trafficking, which are prevalent in Southeast Asia.

The relevant law enforcement agencies, financial intelligence units, policy and supervisory agencies will continue to stay vigilant of the risks identified and raise the private sector’s risks awareness. Financial institutions and designated non-financial businesses and professionals (such as corporate service providers and precious stones and metals dealers) should also take reference from the Environmental Crime ML NRA in assessing their environmental crime ML risks and enhance their controls as appropriate.

Terrorism Financing National Risk Assessment 2020

In 2020, Singapore conducted a Terrorism Financing (TF) National Risk Assessment (NRA). The TF NRA was the culmination of experience and observations from all relevant competent authorities over the past few years, and included inputs from the private sector and academia. It sought to deepen the understanding by law enforcement agencies, supervisors/regulators and the private sector of Singapore’s key TF threats and vulnerabilities, so that appropriate prevention and mitigation measures may be taken.

The TF NRA has found that:

• Allocate law enforcement, financial intelligence and supervisory resources on a risk-sensitive basis
• Singapore continues to be exposed to TF threats posed by terrorist groups both regionally and internationally, in particular the propensity for individuals _­ 1 in Singapore to be radicalised and influenced to carry out TF activities. [1] Local residents and foreign workers.
• Certain sectors, notably money remittance (or payment service providers carrying out cross-border money transfer service) and banks, are more inherently vulnerable to TF threats, given the relative ease in which their services may be accessed, coupled with Singapore’s status as a financial and transport hub and proximity to countries exposed to terrorism activities.
  

Competent authorities in Singapore are cognisant of our TF threats and take a whole-of-government approach to combatting them. Our law enforcement agencies have robust capabilities to counter TF, as evidenced by the TF convictions in recent years. Supervisors and relevant authorities have been engaging relevant private sector entities on their TF risks, and this has improved their risk awareness and understanding, and allowed them to strengthen their measures to mitigate TF risks. Private sector entities should continue to incorporate the TF NRA findings in their risk-based approach to countering TF.

• Terrorism Financing National Risk Assessment 2020 (PDF, 3.5MB)
• Annex - Terrorism Financing National Risk Assessment 2020 (PDF, 165KB)
• Infographic - Terrorism Financing National Risk Assessment (JPEG, 1.2MB)

National Strategy for Countering the Financing of Terrorism (CFT)

Taking into account the findings of the Terrorism Financing (TF) NRA 2020, Singapore formulated our National Strategy for Countering the Financing of Terrorism (CFT). The National CFT Strategy forms the blueprint that outlines Singapore’s national approach to address our TF risks and serves as the roadmap to guide the development of future action plans to effectively prevent, detect, investigate, and enforce against TF. It also enhances the coordination of actions across law enforcement agencies, policy makers, regulators and supervisors, and as appropriate, the private sector, in Singapore.

Singapore has adopted a five-point strategy which comprises:

1. Coordinated and Comprehensive Risk Identification;
2. Strong Legal and Sanctions Frameworks;
3. Robust Regulatory Regime and Risk Targeted Supervisory Framework;
4. Decisive Law Enforcement Actions; and
5. International Partnerships and Cooperation.

As necessary, the relevant law enforcement, policy and supervisory agencies have adopted action plans as guided by the National CFT Strategy.

• National Strategy for Countering the Financing of Terrorism (PDF, 900KB)