A STR or disclosure of information can be made to a Suspicious Transaction Reporting Officer as defined under the CDSA, or a police officer (which include a Suspicious Transaction Reporting Officer) under the TSOFA. In practice, the STR or disclosure can be made directly to STRO, which is the central agency in Singapore for the receipt, analysis and dissemination of STRs.
The Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act, commonly known as the CDSA, is the primary legislation enacted to combat money laundering in Singapore.
The CDSA criminalises the laundering of proceeds derived from more than 360 drug trafficking and other serious offences and also allows for the confiscation of such proceeds. Section 39(1) of the CDSA makes it mandatory for a person, who in the course of his business or employment, to lodge a Suspicious Transaction Report (STR) if he knows or has reason to suspect that any property may be connected to a criminal activity. The failure to do so may constitute a criminal offence. |
The Terrorism (Suppression of Financing) Act (TSOFA) was passed on 8 July 2002 by Parliament to give effect to the International Convention for the Suppression of the Financing of Terrorism which Singapore signed on 18 December 2001.
The TSOFA not only criminalises terrorism financing but also imposes a duty on everyone to provide information pertaining to the terrorism financing to the Police. This obligation is laid out under Sections 8 and 10 of the TSOFA. The failure to do so may constitute a criminal offence. |
A STR or disclosure of information can be made to a Suspicious Transaction Reporting Officer as defined under the CDSA, or a police officer (which include a Suspicious Transaction Reporting Officer) under the TSOFA. In practice, the STR or disclosure can be made directly to STRO, which is the central agency in Singapore for the receipt, analysis and dissemination of STRs.
Money laundering is a problem of international proportion. The laundering of proceeds of crime allows criminals to legitimise their ill-gotten gains, and enables them to enjoy their fruits of crime with impunity. This in turn provides them with greater incentive to commit more financial crimes. In addition, terrorist attacks in countries and cities in many parts of the world have increased the focus of governments worldwide on countering terrorism and the financing of terrorism.
As Singapore is known to be a financial hub, we cannot rule out the possibility that money launderers or other criminals may want to abuse our financial infrastructure to launder their criminal proceeds or further their illicit activities. There is therefore a need for us to be constantly vigilant and report any suspicious financial transaction.
STRs play an important role in combating money laundering and terrorism financing. A high level of suspicious transaction reporting is also an internationally accepted indicator of the existence of a strong anti-money laundering and counter-terrorism financing regime. In this regard, STRO's constant efforts to encourage the increase in both the quantity and quality of STRs have met with a good degree of success.
Since the introduction of the CDSA in 1999, and the establishment of STRO in January 2000, the number of STRs received by STRO has risen steadily every year. These STRs have also led to the detection of a number of significant cases, some of which were not even discovered by the victims had it not been for the STR.
As money laundering and terrorism financing are often transnational crimes that are not bound by geographical boundaries or sovereign jurisdiction, it is imperative that STRO is allowed to cooperate and exchange relevant information with its foreign counterparts.
Under the CDSA, STRO is authorised to share information with its foreign counterparts provided there is an arrangement with the foreign agency for the sharing of information on the basis of reciprocity and confidentiality. Any information shared is intended for intelligence or investigation purposes only and cannot be used as evidence in court. The arrangement can be in the form of a Memorandum of Understanding (MOU), and for this purpose, STRO has signed MOUs with 13 foreign countries/jurisdictions and is actively involved in negotiations with a number of other countries/jurisdictions.
In Singapore, industry regulators (e.g. the Monetary Authority of Singapore (MAS) for financial institutions) may also issue directives on the various AML/CFT measures which would include STR reporting.
STRO, as the central agency for the receipt of all STRs, provides inputs to the respective regulators on their guidelines. These include the manner of reporting STRs (such as the design of the reporting forms and procedures for reporting STRs), advice on ML/TF typologies, as well as the types of suspicious transactions that the respective industries should look out for. STRO also provides general guidance on STR reporting in its publications such as the STRO/CAD Annual Report, the STRO/CAD AML/CFT Handbook and Reports from STRO, a regular publication by STRO which include information on the latest ML/TF trends and typologies.
The following table show a list of some of the Notices/ Guidance Notes that have been issued by the regulators with STRO's inputs:
| Table 1: List of Notices/ Guidance Notes by MAS and Other Competent Authorities |
| Approved Trustees |
Refer to MAS Notice SFA13-N01* |
| Auditors |
Refer to SAP19 by the Institute of Certified Public Accountants of Singapore at http://www.icpas.org.sg |
| Banks |
Refer to MAS Notice 626* |
| Capital Markets Service Licensees and Exempt Persons |
Refer to MAS Notice SFA04-N02* |
| Finance Companies |
Refer to MAS Notice 824* |
| Financial Advisers |
Refer to MAS Notice FAA-N06* |
| Lawyers & Notaries |
Refer to "Guidelines on Prevention of Money Laundering and the Funding of Terrorist Activities, dated 1 March 2003" by the Law Society of Singapore at http://www.lawsociety.org.sg |
| Life Insurers |
Refer to MAS Notice 314* |
| Merchant Banks |
Refer to MAS Notice 1014* |
| Money-Changer's Licence and Remittance Licencees |
Refer to MAS Notice 3001* |
| Real Estate Agents |
Refer to "Guidelines on the Prevention of Money Laundering and Countering the Financing of Terrorism for Real Estate Agents" on the IRAS website |
| Trust Companies |
Refer to MAS Notice TCA-N03* |
* the respective MAS Notices can be found in MAS's website at http://www.mas.gov.sg
Note:
The above mentioned list of STR reporting entities is non-exhaustive. If you or your organisation do not fall within the abovementioned reporting entities, you may wish to lodge your STR using our Generic Forms.
- Click here to download form for legal persons (e.g. companies).
- Click here to download form for natural persons.
Under Section 39 of the CDSA, it is mandatory for any person to lodge an STR if he knows or has reason to suspect that any property may be connected to a criminal activity. The failure to do so may constitute a criminal offence.
If in the course of your trade, profession, business or employment, you have reason to believe that any property or transaction may be connected to a criminal activity, you can lodge a STR with STRO by either submitting it in writing, via email or via our web-based system:
Head, Suspicious Transaction Reporting Office (Analysis)
Commercial Affairs Department
391 New Bridge Road #06-701
Police Cantonment Complex Block D
Singapore 088762
The following information should be contained in the report:
- A detailed account of the relevant facts and nature of the transaction;
- Copies of the relevant documents, if available; and
- Your name, NRIC / passport number, contact number and address.
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Alternatively, if your company has a valid STROLLS user account, your authorised officer may lodge an STR via STROLLS. You may wish to email STRO@spf.gov.sg to find out if your company has a valid STROLLS account. |
Please click here for more information.