Singapore Bullion Market Association

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Safeguarding Singapore’s Precious Metals Industry

By Paramjit Singh, Registrar of Regulated Dealers, Director, Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) division, Ministry of Law

Published on June 5, 2019

Precious stones and precious metals are portable, valuable, and easily convertible to cash. These characteristics expose the Precious Stones and Precious Metals Dealers (PSMD) sector to inherent money laundering (ML) and terrorism financing (TF) risks. On 10 April 2019, Singapore introduced a new anti-money laundering and countering the financing of terrorism (AML/CFT) regime to mitigate these risks, and raise AML/CFT standards and trust in the sector.


ML enables criminals to commit crimes by obscuring the proceeds of their crimes, while TF refers to the use of funds/assets to support terrorist organisations and terrorism. Singapore has a strong regulatory AML/CFT framework for prevention, supervision, enforcement, confiscation of the proceeds of crime, and targeted financial sanctions against terrorism and proliferation financing. Singapore also has a good framework for international coordination on AML/CFT and has in place mechanisms to assess and mitigate the ML and TF risks identified. There is robust supervision of the financial sector, with regular engagements fostering a deep understanding of AML/CFT issues within the industry. Designated non-financial sectors, such as pawnbrokers, are also subject to a comprehensive range of AML/CFT measures.

The new regime will strengthen existing AML/CFT measures for the PSMD sector by establishing a comprehensive supervisory and regulatory regime that is risk-focused. It seeks to prevent dealing in precious stones and precious metals from being used to facilitate ML and TF in two ways. First, by registering all persons who carry on a business of regulated dealing or business as an intermediary for regulated dealing; and second, by introducing additional measures beyond the cash transaction reporting regime that was introduced in 2014.


Unless exempted, regulated dealers must register with the Registrar of Regulated Dealers established under the Ministry of Law. The Registrar may refuse to grant or renew registration under various circumstances, for example, if the dealer is not a fit and proper person as assessed by the Registrar. This seeks to prevent criminals or their associates from holding a controlling or management function in the regulated dealer. Registered dealers are required to abide by the conditions of registration.

Regulated dealers are also required to comply with the following measures:

  • Transaction-based requirements, including filing cash transaction reports; filing suspicious transaction reports; performing customer due diligence (CDD) measures; and keeping records of transactions for which CDD measures are performed and information obtained through CDD measures; and
  • Entity-based requirements, including conducting ML/TF risk assessments posed by its customers and transactions; and putting in place internal policies, procedures and controls to mitigate these risks amongst other requirements.

These measures are aligned with recommendations issued by the Financial Action Task Force, the international standard-setting body for AML/CFT standards.


The Ministry of Law has been working closely with the industry associations such as the Singapore Bullion Market Association (SBMA) in developing the AML/CFT regime. We will continue to work closely with the industry associations to conduct outreach and engagement sessions to help the regulated dealers understand the requirements of the new regime, manage compliance costs, and identify and address potential difficulties the sector might face in meeting the requirements under the new regime. Together, our efforts will enable Singapore to combat crime and improve security, encouraging growth and investments in the PSMD sector.

PARAMJIT SINGH is the Registrar of Regulated Dealers and Director of AML/CFT division in the Ministry of Law. He leads the division in the formulation and implementation of the AML/CFT supervisory and regulatory regime for the PSMD sector. He has held a long career in law and regulatory enforcement, spanning more than three decades, which includes heading the Commercial Crime division of the Singapore Police Force and the Investigation division of the Casino Regulatory Authority.