Higher Risk
 
Medium Risk
 
Info n/a
 
Lower Risk
Bilateral exchange of
information Agreements
in place?
Singapore has over 60 Double Taxation Treaties in
place some including evasion of taxes, including
China. In July, 2009, signed protocol to its tax
conventions with Belgium re exchange of tax
information
.
Sanctions:

None applicable


Offshore Jurisdiction Blacklists:

As a recognised offshore finance jurisdiction this country may fall
under various country offshore jurisdiction blacklists.


US State Department Money Laundering Report - 2012:

Singapore is a major international financial and investment center
as well as a major offshore financial center. Secrecy protections,
a lack of routine large currency reporting requirements, and the
size and growth of Singapore’s private banking and assets
management sector pose significant money laundering (ML) risks
and make the jurisdiction a potentially attractive money
laundering/terrorist financing destination for drug traffickers,
transnational criminals, foreign corrupt officials, terrorist
organizations and their supporters. Authorities have taken action
against Jemaah Islamiyah and its members and have identified
and frozen terrorist assets held in Singapore. Terrorist financing
in general remains a risk.

As of December 5, 2011, there were 39 offshore banks in
operation, all foreign-owned. Singapore is a center for offshore
private banking and asset management. Assets under
management in Singapore total approximately S$1.4 trillion
(approximately $1.09 trillion). As of June 2010, Singapore had at
least $300 billion in foreign funds under management. Singapore
does not permit shell banks or anonymous accounts.

Singapore has nine free trade zones (FTZs), six for seaborne
cargo and three for airfreight, regulated under the Free Trade
Zone Act. The FTZs may be used for storage, repackaging of
import and export cargo, assembly and other manufacturing
activities approved by the Director General of Customs in
conjunction with the Ministry of Finance.

For additional information focusing on terrorist financing, please
refer to the Department of State’s Country Reports on Terrorism,
which can be found here: http://www.state.gov/j/ct/rls/crt/

Do Financial Institutions engage in currency transactions related
to international narcotics trafficking that include significant
amounts of US currency; currency derived from illegal sales in the
U.S.; or that otherwise significantly affect the U.S.: NO

Criminalization of Money Laundering:

“All serious crimes” approach or “list” approach to predicate
crimes: List approach

Legal persons covered: criminally: YES civilly: YES

Know-your-customer (KYC) rules:

Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: YES

KYC covered entities: Banks, financial institutions, finance
companies, merchant banks, life insurers, brokers, securities
dealers, investment advisors, futures brokers and advisors, trust
companies, approved trustees, and money changers and remitters

Suspicious Transaction Reporting (STR) Requirements:

Number of STRs received and time frame: 11,934 in 2010

Number of CTRs received and time frame: Not applicable

STR covered entities: Banks, auditors, financial advisors, capital
market service licensees and exempt persons, finance
companies, lawyers, notaries, merchant banks, life insurers, trust
companies, approved trustees, real estate agents and money
changers and remitters

Money Laundering Criminal Prosecutions/Convictions:

Prosecutions: 14 in 2010

Convictions: 18 in 2010

Records exchange mechanism:

With U.S.: MLAT: NO Other mechanism: YES

With other governments/jurisdictions: YES

Singapore is a member of the Financial Action Task Force (FATF)
and the Asia/Pacific Group on Money Laundering, a FATF-style
regional body. Its most recent mutual evaluation can be found
here: http://www.fatf-gafi.org/dataoecd/36/42/40453164.pdf

Enforcement and implementation issues and comments:

Singapore has a comprehensive suspicious transaction reporting
regime and applies AML/CFT requirements to a broad range of
financial institutions. Currently, there is no requirement for
reporting large transactions, which limits the ability to track
significant financial movements. Singapore should consider the
adoption of such reporting.

Singapore’s legal system generally provides for the investigation
and prosecution of money laundering offenses. However, the
implementation of these laws is uneven, particularly in prosecuting
money laundering as a stand-alone offense, and investigating
foreign-sourced cases. Singaporean police are fairly successful at
identifying domestic predicate offenses, and include ancillary
money laundering charges as appropriate. Singapore should
more aggressively pursue domestic stand-alone money
laundering offenses as well.

Singapore’s large, stable, and sophisticated financial center may
be attractive as a conduit for laundering proceeds generated by
foreign criminal activities, including official corruption. The
Suspicious Transaction Reporting Office (STRO) and criminal
investigators are encouraged to identify money laundering that
originates from foreign predicate offenses, and use stand-alone
money laundering charges to prosecute third-party offenders in
Singapore.

____________________________________________________

US State Dept Narcotics Report 2012:

The Government of Singapore (GOS) enforces stringent counter-
narcotics policies through strict laws -- including the death penalty
and corporal punishment -- vigorous law enforcement, and active
prevention programs. Singapore is not a producer of narcotics,
but as a major regional financial and transportation center, it is an
attractive target for money launderers and drug transshipment.
Singapore is ranked as one of the least corrupt countries in the
world. Corruption cases involving Singapore's counter-narcotics
and law enforcement agencies are extremely rare. Singapore
officers regularly attend U.S.-sponsored training programs as well
as regional forums on drug control. In recent years, Singapore
has begun training ASEAN narcotics officers in partnership with
French and Australian counterparts. In May 2011, Singapore
Central Narcotics Bureau officials partnered with UN Colombo
Plan officials to deliver a one-week narcotics course to officers
from South and East Asian nations including Afghanistan,
Pakistan, Sri Lanka, Bhutan, Timor-Leste, and others.

According to GOS figures, during 2010, 1772 drug offenders were
arrested compared to 1882 arrested in 2009. Heroin and
methamphetamine remain the top two drugs of choice in
Singapore accounting for 88 percent of the drug abusers
arrested, up from 84 percent in 2009. In 2010 Singapore saw an
increase in seizures of almost all drug types. In 2010, Singapore
seized 48.45 kg of Heroin #3, a 68 percent increase from 29.14
kg in 2009; 8.51 kg of Cannabis, compared to 5.3 kg in 2009;
5.53 kg of methamphetamine compared to 3.9 kg in 2009; 12.14
kg of ketamine compared to 9.3 kg in 2009; 43,320 tablets of
Nimetazepan-AKA Erimin-5 as compared to 24,124 tablets in
2009. Also seized were 8,085 tablets of MDMA (ecstasy), 332
tablets of methamphetamine (Yaba), and 292 tablets of
Buprenorphine (Subutex).

In 2010, there was no known production of illicit narcotics in
Singapore. Singapore has been used as a transit point for
narcotics moving to destinations such as Indonesia, China, and
Hong Kong via parcels, maritime containers and air cargo. Air and
maritime ferry passengers have also frequently transited
Singapore in possession of narcotics for delivery to other
countries such as Indonesia. Points of origin have included
Malaysia, India, Thailand, and Pakistan. Singapore is a one of the
world’s largest licit producers of ephedrine and pseudo-ephedrine
(precursor chemicals for the production of methamphetamine)
and also acetic anhydride (precursor chemical for the production
of heroin). Precursor chemicals, including acetic anhydride, have
also transited Singapore from South Korea and China en route to
destinations such as Pakistan, destined for heroin conversion
laboratories in Afghanistan. Singapore is one of the busiest
transshipment ports in the world. With few exceptions, Singapore
does not screen containerized shipments unless they enter its
customs territory. Neither Singapore Customs nor the Immigration
and Checkpoint Authority (ICA) keep data on in-transit or
transshipped cargo unless there is a Singapore consignee
involved in the shipment. In 2010, Singapore’s Free Trade Zone
(FTZ) was exploited on numerous occasions by Pakistani
nationals and others to transship narcotics and precursor
chemicals to, among other countries, Mexico, Israel, the United
Kingdom, and the United States.

As a matter of government policy, the GOS neither encourages
nor facilitates illicit production or distribution of narcotics,
psychotropic drugs, or other controlled substances, nor the
laundering of related proceeds. Singapore continues to pursue a
strategy of demand and supply reduction for drugs. The GOS
worked closely with numerous international groups dedicated to
drug education, including the Partnership for a Drug-Free
America. In addition to arresting drug traffickers, Singapore
focuses on arresting and detaining drug abusers for treatment
and rehabilitation, providing drug detoxification and rehabilitation,
and offering vigorous drug education in its schools. Singaporeans
and permanent residents are subject to random drug tests. The
Misuse of Drugs Act gives the Singapore Central Narcotics
Bureau (CNB) the authority to remand all drug abusers to
rehabilitation centers for mandatory treatment and rehabilitation.
Since 1999, individuals testing positive for consumption of
narcotics have been held accountable for narcotics consumed
abroad as well as in Singapore.

Singapore is a party to the 1988 UN Drug Convention. Singapore
and the United States continue to cooperate in extradition matters
under the 1931 U.S.-UK Extradition Treaty. Singapore and the
United States signed a Drug Designation Agreement (DDA) in
November 2000, and a mutual assistance agreement limited to
drug cases. Singapore has signed mutual legal assistance
agreements with Hong Kong and ASEAN. The United States and
Singapore have held discussions on a possible bilateral MLAT,
most recently in December 2005, although there have been no
formal negotiations since 2004. Singapore is a party to the UN
Convention against Transnational Organized Crime and the UN
Corruption Convention. In April 2006, Singapore amended
domestic legislation to allow for mutual legal assistance
cooperation with countries for which Singapore does not have a
bilateral treaty.

____________________________________________________

US State Dept Trafficking in Persons Report 2011
(introduction):

(Tier 2)

Singapore is a destination country for men, women and girls
subjected to sex trafficking and forced labor. There are over 1.1
million foreign workers in Singapore, who make up over one-third
of Singapore’s total labor force. Migrating from Thailand, Burma,
Philippines, Indonesia, Malaysia, Vietnam, China, India, Sri Lanka,
Bangladesh, and elsewhere in Asia, the majority of foreign
workers are unskilled and semi-skilled laborers employed in
construction, domestic households, and the hospitality and
service industries. During the year, there was greater reporting on
victims of forced labor identified by NGOs and foreign missions on
long-haul fishing boats that dock in Southeast Asian ports,
including Singapore. Workers reported severe abuse by fishing
boat captains, the inability to disembark from their vessels, the
inability to terminate their contracts, and the nonpayment of
wages. Many foreign workers face deception and fraud by
recruiters about the ultimate nature of their employment or salary.
Foreign workers also reported confiscation of their passports,
restrictions on their movements, illegal withholding of their pay,
threats of forced repatriation without pay, or physical or sexual
abuse – all potential indicators of trafficking.

There were reports of employers hiring Singaporean repatriation
companies to seize, confine, and escort, including through the
use of assaults, threats, and coercion, to the airport foreign
workers, sometimes in order to prevent workers from complaining
of abuses, including conditions of forced labor, or seeking redress
through the Ministry of Manpower. There have been some reports
of employers who tried to get their workers deported by canceling
their work permits and later alerting the police of their expired
immigration status.

Many migrant workers, including those in domestic service, in
Singapore face debts to recruitment agencies in both Singapore
and their home countries associated with their employment, which
makes them vulnerable to forced labor. A 2010 report produced
by NGOs found that, on average, Indian, Bangladeshi, and
Chinese migrant workers in Singapore paid fees to employment
agencies that constitute at least 10 months of their potential
earnings such debt makes migrants vulnerable to forced labor,
including debt bondage. Exorbitant fees are sometimes the result
of multiple layers of sub-contracting to smaller agencies and
individual recruiters, commissions paid to Singaporean agencies,
and sometimes, kickbacks to Singaporean employers. To hide
illegal fees, agencies and employers sometimes mask them as
payments from the worker for personal loans or as other
payments. The practice of arbitrary fines, fees, and other
deductions from salary made it difficult for workers to understand
how their wages were calculated, particularly as many workers did
not possess a copy of their contract, and could be used by
traffickers to keep workers in a situation of debt bondage. Many
foreign workers have credible fears of losing their work visas and
being deported, since employers have the ability to repatriate
workers at anytime during their contracts. Additionally, low-skilled
workers are prohibited or severely restricted from seeking
alternative employment and transferring employers, and
Singaporean employers have unilateral rights to cancel their
employees’ work permits and can submit complaints about worker
behavior to have future employment bans placed on them.

Some women from Thailand, the Philippines, China, Vietnam,
India, Sri Lanka, and Nepal are recruited in their home countries
with offers of legitimate employment but upon arrival in Singapore,
are deceived or forced into prostitution. Some women from these
countries enter Singapore with the intention of engaging in
prostitution but upon arrival are subjected to forced prostitution
under the threat of serious harm, including financial harm. Sex
trafficking victims often enter Singapore on tourist visas arranged
by their recruiters, though there were reports that victims enter
Singapore on six-month entertainment visas. Some foreign women
in “forest brothels” located on public lands near migrant worker
dormitories are reportedly victims of trafficking. It is believed
substantial recruitment networks, including organized crime
syndicates, are involved in international sex trafficking of women
and girls to Singapore. Singaporean men have reportedly been a
source of demand for child sex tourism in Southeast Asia. The
Government of Singapore does not fully comply with the minimum
standards for the elimination of trafficking; however, it is making
significant efforts to do so. During the year, the government
reversed its longstanding approach of denying a significant labor
trafficking problem in the country and acknowledged its need to
take more robust efforts to tackle problems of both forced labor
and forced prostitution among Singapore’s foreign migrant
population. Authorities formed an interagency committee to
combat trafficking, and announced that Singapore would adopt
the 2000 UN TIP Protocol’s definition of trafficking as the
government’s working definition, though the government has not
yet ratified the 2000 UN TIP Protocol.

The government made initial efforts to adopt proactive trafficking
victim identification procedures among foreign women arrested for
prostitution, though it has yet to make similar efforts among
foreign laborers. The government reported six sex trafficking
convictions; these offenders were convicted of living off the
earnings of prostitution and other related offenses, as Singapore
does not have a specific anti-trafficking law. Some imposed
sentences were below one year’s imprisonment and as such, were
inadequate punishments for this serious crime. Despite ongoing
reports of forced labor in Singapore, the government did not
prosecute or convict any offenders of labor trafficking during the
reporting period. Despite its financial resources and capacity, the
government should have been more successful in proactively
identifying and assisting victims of both sex and labor trafficking.

For full report click here

____________________________________________________

US State Dept Terrorism Report 2010

Overview: Singapore continued its strong bilateral and multilateral
counterterrorism intelligence and law enforcement cooperation.
As of December, Singapore held in detention 15 persons with
links to terrorist groups. Detainees included members of Jemaah
Islamiya (JI) who had plotted to carry out attacks in Singapore in
the past and members of the Moro Islamic Liberation Front (MILF).
Singapore released 48 persons on Restriction Orders (RO) and
two on Suspension Direction (SD); detainees released on ROs
and SDs were monitored by the Singapore authorities and
required to report to authorities on a regular basis. Among those
subjected to religious rehabilitation, there are no reported cases
of recidivism to date.

Law Enforcement and Prosecutions: Singapore used its Internal
Security Act (ISA) to arrest and detain suspected terrorists without
trial. The ISA authorizes the minister for home affairs, with the
consent of the president, to order detention without filing charges
if it is determined that a person poses a threat to national
security. The initial detention may be for up to two years, and the
minister for home affairs may renew the detention for an unlimited
number of additional periods of up to two years at a time with the
president's consent.

In August, Singapore passed the Hostage Taking Act 2010, which
gives effect to the International Convention against the Taking of
Hostages.

Singapore’s law enforcement actions included:

* In January, Singapore detained JI and MILF member Mohammed
Azmi Ali for terrorist activities and placed him in detention under
Singapore's Internal Security Act (ISA). Azmi had originally fled
Singapore in 2001 following the government’s crackdown on JI.
* In February, Singapore released self-radicalized detainee Abdul
Basheer Abdul Kader under SD. The government had originally
detained Basheer in April 2007 after he had made plans to go to
Afghanistan to engage in militant activities.
* In July, Singapore placed Muhammad Anwar Jailani and
Muhammad Thahir Shaik Dawood directly on to RO. Both Jailani
and Thahir had links to Anwar al-Aulaqi. According to press
reports, Thahir had gone to Yemen to seek out al-Aulaqi to
engage in militant activities outside of Singapore. He also enrolled
in an educational institution run by an associate of Usama bin
Ladin.
* Also in July, Singapore announced the detention of soldier
Muhammad Fadil Abdul Hamid under Singapore's Internal
Security Act. The government announced that Fadil had become
self-radicalized and had made contact with al-Qa`ida in the
Arabian Peninsula operative Anwar al-Aulaqi, who encouraged
him to go to Afghanistan to engage in militant activities.
Authorities arrested Fadil before he could depart Singapore.

Countering Terrorist Finance: Singapore cooperated with the
United States to identify and freeze terrorist assets. The opening
of Singapore's two casinos in 2010 increased concerns about the
potential for illicit flows to pass through Singapore. Singapore has
implemented legal and regulatory changes involving cash
transactions at casinos to better align itself with the international
standards for anti-money laundering/counterterrorist financing
regimes.

Regional and International Cooperation: In June, the Republic of
Singapore Navy participated in the annual Southeast Asia
Cooperation Against Terrorism exercise. In November, the
Singapore Armed Forces participated in Cooperation 2010, a nine-
day joint counterterrorism training exercise with a personnel
contingent from China's People's Liberation Army.

Countering Radicalization and Extremism: Singapore maintained a
de-radicalization program that focused on countering detainees'
extremist ideology. Detainees are required to undergo a program
of religious counseling with a group of volunteer religious
counselors. Singapore enlists the support of religious teachers
and scholars to study JI's ideology to develop teachings to
counter the group within Singapore's Muslim community and
provide counseling to detainees. Religious counseling for
detainees continued after release from detention. Among those
individuals released from detention, there were no reported cases
of recidivism.
Tables & Rankings
Are there Sanctions in force against it? (UN/EU/US)
N
?
Is it on FATF list of non-cooperative countries?
N
?
Is it on OECD list of uncooperative Tax Havens?
N
?
OECD - Implementation status of Tax Standard
White
?
Is it on EU 'white' list of equivalent jurisdictions?
Y
?
Offshore Finance Center (Original IMF List)?
Y
?
Is it on the US Secretary of Treasury list of jurisdictions of
Primary Money Laundering concern?
N
?
Is it on the US Secretary of State list of jurisdictions
identified to be supporters of International Terrorism?
N
?
Is it on US Department of State International Narcotics
Control Majors List?
N
?
US Dept of State Money Laundering assessment (INCSR)
PC
?
Government Actions (For further info see INCRS below):
 
?
-  Criminalized Drug Money Laundering?
Y
 
-  Criminalized Beyond Drugs?
Y
 
-  Record Large Transactions?
N
 
-  Maintain Records Over Time?
Y
 
-  Report Suspicious Transactions?(NMP)?
Y
 
-  Egmont Financial Intelligence Units?
Y
 
-  System for Identifying/Forfeiting Assets?
Y
 
-  Arrangements for Asset Sharing?
Y
 
-  Cooperates with International Law Enforcement?
Y
 
-  International Transportation of Currency?
Y
 
-  Ability to Freeze Terrorist Assets w/o Delay?
Y
 
-  Disclosure Protection "Safe Harbor"?
Y
 
-  Criminalized Financing of Terrorism?
Y
 
-  States Party to 1988 UN Convention?
Y
 
-  International Terrorism Financing Convention?
Y
 
 
Ranking
2011
Ranking
2010
 
Corruption (Transparency International)
5 (out of
183)
1 (out of
178)
?
Ease of doing business (World Bank)
1 (out of
183)
1 (out of
183)
?
FATF 40 + 9 recommendations
Mutual Evaluation Report: 2008
Further Tables
C
L
P
N
N/A
    C  -  Fully Compliant ,   
    L  -  Largely Compliant,    
    P  -  Partially Compliant    
    N  -  Non-Compliant
11
32
4
2
0
Legal Systems
 
1. Money Laundering Offence
P
 
14. Protection & no tipping-off
L
2. ML offence – mental element and
corporate liability
L
 
15. Internal controls,
compliance & audit
L
3. Confiscation and provisional
measures
L
 
16. DNFBP – R.13-15 & 21
P
4. Secrecy laws consistent with the
Recommendations
C
 
17. Sanctions
L
5. Customer due diligence
L
 
18. Shell banks
C
6. Politically exposed persons
L
 
19. Other forms of reporting
C
7. Correspondent banking
C
 
20. Other NFBP & secure
transaction techniques
L
8. New technologies & non
face-to-face business
L
 
21. Special attention for
higher risk countries
L
9. Third parties and introducers
L
 
22. Foreign branches &
subsidiaries
L
10. Record keeping
L
 
23. Regulation, supervision
and monitoring
N
11. Unusual transactions
L
 
24. DNFBP - regulation,
supervision and monitoring
L
12. Designated Non-Financial
Businesses and Professions – R.5,
6, 8-11
N
 
25. Guidelines & Feedback
L
13. Suspicious transaction reporting
L
     
Institutional and other
measures
 
26. The FIU
L
 
31. National co-operation
C
27. Law enforcement authorities
L
 
32. Statistics
L
28. Powers of competent authorities
C
 
33. Legal persons –
beneficial owners
P
29. Supervisors
L
 
34. Legal arrangements –
beneficial owners
P
30. Resources, integrity and training
C
 
 
 
International Co-operation
 
35. Conventions
L
 
38. MLA on confiscation and
freezing
L
36. Mutual legal assistance (MLA)
L
 
39. Extradition
C
37. Dual criminality
C
 
40. Other forms of
co-operation
C
Nine Special
Recommendations
 
SR.I Implement UN instruments
L
 
SR VI AML requirements for
money/value transfer services
L
SR.II Criminalise terrorist financing
L
 
SR VII Wire transfer rules
L
SR.III Freeze and confiscate
terrorist assets
L
 
SR.VIII Non profit
organisations
L
SR.IV Suspicious transaction
reporting
C
 
SR.IX Cross Border
Declaration & Disclosure
L
SR.V International co-operation
L
 
 
 
*In February, 2011, Singapore was removed from the regular follow-up
process and agreed that it should now report on any further
improvements to its Anti-Money Laundering/Combating the Financing
of Terrorism (AML/CFT) system on a biennial basis.
SINGAPORE
KnowYourCountry
-  Know Your Customer Provisions
Y
 
-  Criminalized Tipping Off?
Y
 
-  Report Suspected Terrorist Financing?
Y
 
-  State Party to United Nations TOC?
Y
 
-  State Party to United Nations CAC?
Y
 
__________________________________________________

AML News / Updates

June 26, 2011  -  New report by the Global Forum on Transparency and
Exchange of Information to evaluate the country's legal and regulatory
frameworks re exchange of information is made available.

Read Report


March 3, 2011  -  FATF removed Singapore from the regular follow-up
process and agreed that it should now report on any further
improvements to its Anti-Money Laundering/Combating the Financing of
Terrorism (AML/CFT) system on a biennial basis.

Read More


Links:

Worldwide AML Legislation (International Bar Association)
Local AML News / Sanctions
Tax Information
Business Information
Last Updated:   16 April 2012