Singapore issues sanctions and restrictions against Russia

      On 5 March, the Ministry of Foreign Affairs Singapore released details of Singapore’s new sanctions against Russia in response to the invasion into Ukraine.

      The sanctions aim to constrain Russia’s capacity to conduct war against Ukraine and undermine its sovereignty in the following manner:

      • Export controls – impose export controls on items that can directly be used as weapons to inflict harm on or to subjugate the Ukrainians and items that contribute to offensive cyber operations.
      • Financial measures – impose financial sanctions on designated Russian banks, entities and activities in Russia and fund-raising activities benefiting the Russian government.

      Export controls

      The Singapore Strategic Goods Control System regulates the transfer (export, transit, and transhipment) of strategic goods which are generally military weapons or their parts as well as high-technology goods that could be used for both commercial and military purposes. In order to restrain Russia’s capacity to conduct war in Ukraine and cyber aggression, all permit operators to Russia involving all items on the list of military goods under the Strategic Goods (Control) Order (SGCO) 2021 will be rejected. All category codes for electronics, computers, telecommunications and information security on the list of Dual-Use Goods under the SGCO will also be rejected.

      Financial Controls

      All financial institutions in Singapore will be prohibited from carrying out the following activities:

      a) entering into transactions or establishing business relationships with the following Russian Banks:

      • VTB Bank Public Joint Stock Company
      • The Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank
      • Promsvyazbank Public Joint Stock Company
      • Bank Rossiya.

      Financial institutions with existing business relationships with the above banks are required to freeze relevant assets and funds.

      b) provide financial or financial services in relation to the export from Singapore or any other jurisdiction of goods subject to Singapore’s export controls on Russia.

      c) provide financial services in relation to designated Russian non-bank entities which are involved in activities as above, (b). Financial institutions with existing business relationships to freeze all relevant assets and funds.

      d) enter into transactions or arrangements, provide financial services that facilitate fund raising by relevant Russian entities such as the Russian government, Central Bank of Russian Federation and any entities controlled by the forementioned entities.

      e) enter into transactions or provide financial services in relation to sectors in the breakaway regions of Donetsk and Luhansk such as transport, telecommunication and energy.

      f) enter into or facilitate any transactions involving cryptocurrencies, to circumvent any of the above prohibitions. This extends to non-fungible tokens (NFTs).

      Financial Institutions should take initial steps to review current business operations and transactions to potential exposures to the newly imposed sanctions on Russia. Financial Institutions can expect the Monetary Authority of Singapore (MAS) to issue directions setting out details of the prohibitions. Broadly, MAS requires financial institutions to immediately freeze funds and assets, not enter into financial transactions or provide financial services and inform MAS of any fact or information relation to the relevant assets or funds in relation to the sanctioned entities and/or individuals.

      Financial Institutions are reminded that contravening any MAS regulations would be deemed as an offence and be liable for conviction and/or fine.

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