As a member state of the United Nations (UN), Singapore is committed to implementing the UN Security Council Resolutions (UNSCRs).

Among other measures, the UNSCRs may impose targeted financial sanctions against specific individuals and entities identified by the UN Security Council (or relevant UN Committees) as contributing to a particular threat to, or breach of, international peace and security. For instance, there are UNSCRs issued to address the risks of proliferation of weapons of mass destruction emanating from Iran and the Democratic People’s Republic of Korea.

MAS gives effect to targeted financial sanctions under the UNSCRs 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 (FSM Regulations). The FSM Regulations apply to all financial institutions in Singapore.

Broadly, the FSM Regulations 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: (i) designated individuals, entities or items; or (ii) 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.

Under the Financial Services and Markets Act 2022, a financial institution that contravenes any FSM Regulations is guilty of an offence and is liable on conviction to a fine not exceeding $1 million.

Before engaging in a business relationship or providing a financial service, financial institutions should ensure that they do not deal with designated individuals and entities (as defined in the respective FSM Regulations). Financial institutions are required to screen the names of their customers, including the beneficial owners, against the names (and aliases) of designated individuals and entities.

Financial institutions should also note that aside from the FSM Regulations, there are other targeted financial sanctions (e.g. those found under the Terrorism (Suppression of Financing) Act 2002 More information is available on the IMC-TD website ) that they also have to comply with. More information on terrorist designations and requirements for countering the financing of terrorism can be found at the Ministry of Home Affairs’ website: Countering the Financing of Terrorism .

Financial institutions should seek legal advice on the interpretation and applicability of the FSM Regulations if necessary. If you have any enquiries, please contact us.  

Variable Capital Companies (VCCs) are required to comply with 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.

Non-financial institutions and natural persons in Singapore are similarly required to comply with the sanctions requirements in relation to UN-designated individuals and entities.

The UN Act, which was promulgated in 2001, gives the Minister for Law the power to make regulations that are necessary to comply with the sanctions requirements.

Thus far, Singapore has put in place Regulations to comply with the various UNSCRs, such as those dealing with Iran and the Democratic People’s Republic of Korea. The full texts of the UN Act and the UN Regulations are available at the Singapore Statutes Online .

These Regulations prohibit persons in Singapore from dealing with designated individuals and entities as defined in the respective UN Regulations.

The prohibitions include the following:

• Prohibition against dealing with property of designated persons; and
• Prohibition against provision of resources and services for benefit of designated persons.

Under the UN Act, a person who commits an offence against any Regulations made under the UN Act will be liable on conviction, in the case of an individual, to a fine not exceeding $500,000 or to imprisonment for a term not exceeding 10 years or to both; or in any other case, to a fine of up to $1 million.

Please seek legal advice on the interpretation and applicability of the UN Act and its Regulations or your obligations to comply with the sanctions requirements if necessary. Further enquiries should be sent to your sectoral regulator or supervisor, or where appropriate to MAS at Contact Us page.

Aside from the UN Act and its Regulations, all natural and legal persons also have to comply with other targeted financial sanctions found in the Terrorism (Suppression of Financing) Act . More information on terrorist designation and requirements for countering the financing of terrorism can be found at the Ministry of Home Affairs’ website: Inter-Ministerial Committee – Terrorist Designation (IMC-TD) .

In response to Russia’s invasion of Ukraine, the Singapore Government has imposed financial measures targeted at designated Russian banks, entities and activities in Russia, and fund-raising activities benefiting the Russian government. These measures apply to all financial institutions in Singapore, including banks, finance companies, insurers, capital markets intermediaries, securities exchanges, and payment service providers. Digital payment token service providers are therefore specifically prohibited from facilitating transactions that could aid the circumvention of the financial measures. Details of these financial measures can be found in these Notices:

• Notice SNR-N01 Financial Measures in Relation to Russia (183.1 KB)
• Notice SNR-N02 Financial Measures in Relation to Russia – Non-prohibited Payments and Transactions (132.9 KB)