Strategy for Countering the Financing of Terrorism
INTRODUCTION
Singapore published its Terrorism Financing (TF) National Risk Assessment (NRA) in December 2020.
The TF NRA presented an updated overview of Singapore’s TF risk environment and identified the key TF
threats and vulnerability areas to address as part of the work of our national Countering the Financing of
Terrorism (CFT) system.
TF NRA Findings
2
The TF NRA revealed the following key TF threats and vulnerabilities that are particularly relevant
to Singapore:
a. Key TF Threats
–
While we cannot discount the possibility of a terrorist attack in Singapore, Singapore assesses that
the TF threat of raising and moving of funds in support of terrorists / terrorist organisations / terrorist
activities overseas is currently of greater concern in Singapore’s context.
–
Radicalised individuals pose the most salient TF threat to Singapore.
–
Singapore remains vigilant and cognisant of the global terrorism and TF threat posed by the Islamic
State of Iraq and Syria (ISIS), Al-Qaeda (AQ) and Jemaah Islamiyah (JI), and we remain on the
look-out for potential financing of other existing or new terrorist groups regionally and globally.
b. Key TF Vulnerabilities
1
–
Money remittance services and banks are inherently more vulnerable to TF threats, given the relative
ease with which their services may be accessed, coupled with Singapore’s connectivity as a financial
and transport hub and proximity to countries exposed to terrorist activities.
–
Related to its connectivity, Singapore is also vulnerable as a potential location for cash couriers to
collect or move cash for delivery across borders.
–
Digital payment token service providers (DPTSPs)1, precious stones and metals dealers (PSMDs)
and non-profit organisations (NPOs) are also susceptible to TF in Singapore, particularly in light of
the more nascent regulatory regimes for PSMDs and DPTSPs. International typologies also indicate
Or virtual assets service providers as they may be known elsewhere.
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NATIONAL CFT STRATEGY 2022
that virtual assets, for example digital payment tokens, have been used to support terrorist activities,
and is an emerging area of risks that is being monitored by a number of authorities.
3
Singapore is committed to combatting TF through our continuous efforts to monitor and identify
emerging TF threats and vulnerabilities. We continue to develop and implement effective and risk-targeted
regulatory, supervisory, and enforcement measures to tackle TF risks.
4
This National CFT strategy is an extension of existing overarching policy statements of our antimoney laundering and CFT (AML/CFT) regime. As guided by the AML/CFT Steering Committee (SC),
the National CFT strategy has taken into consideration the findings of the TF NRA 2020 and forms the
blueprint that outlines Singapore’s national approach to address our TF risks. It will pave the way for the
development of a roadmap to translate our strategies into actions as well as serve to guide the development
of future action plans, in this ever-evolving terrorism and TF operational landscape.
5
We have adopted a five-point strategy which comprehensively covers risk identification and
management and mitigation measures. Where necessary, relevant law enforcement, policy and supervisory
agencies have also adopted action plans that are complementary to the National CFT strategy.
Singapore’s Five-Point CFT Strategy
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NATIONAL CFT STRATEGY 2022
Point 1: Coordinated and Comprehensive Risk Identification
To identify our TF risks, Singapore maintains strong inter-agency coordination and has
well established cooperation committees and networks. Agencies work together to review
the TF landscape regularly, taking into account current typologies as well as international
standards and requirements set by international bodies such as the Financial Action Task
Force (FATF) and the United Nations (UN).
Strategy in Action
1.1
Singapore adopts a Whole-of-Government
(WOG) approach to combatting money
laundering (ML), TF and proliferation financing
(PF). This is led by a high-level committee, the
AML/CFT SC, comprising the Permanent
Secretary of the Ministry of Home Affairs (MHA),
Permanent Secretary of the Ministry of Finance
(MOF) and Managing Director of the Monetary
Authority of Singapore (MAS). More than 15
government agencies, including the Internal
Security Department (ISD), the Commercial
Affairs Department (CAD), the Suspicious
Transaction Reporting Office (STRO), sectoral
supervisors from the financial, NPO and PSMD
sectors, are represented at a senior level in the
AML/CFT SC. This ensures high-level policy
direction and commitment to action across
agencies. The operational work of the AML/CFT
SC is supported by the Inter-Agency Committee
(IAC) co-chaired by senior officials from MHA
and MAS.
1.2
The Risks and Typologies Inter-Agency
Group (RTIG), led by MHA and MAS, was
formed in 2017 to specifically oversee the
identification, assessment and mitigation of TF,
ML and PF risks at the WOG level. The RTIG
comprises all relevant supervisory, regulatory,
law enforcement and policy agencies.
1.3
Singapore’s understanding of our TF risks
is also enhanced by the involvement of the private
sector and academia. For example, in 2020, MHA
collaborated with the International Centre for
Political Violence and Terrorism Research under
the S. Rajaratnam School of International Studies
(RSIS) to conduct a regional TF risk assessment
of South Asia and Southeast Asia, which outlined
known TF typologies in these regions.
Looking Ahead
1.4
As the global terrorism and TF landscape
continues to evolve, Singapore remains vigilant to
existing and emerging threats and vulnerabilities
through our comprehensive WOG approach to
monitor, identify and assess TF risks. Relevant
agencies that oversee different sectors and areas
have established a holistic approach to developing
AML/CFT strategies. The development of the
strategies takes into account ground observations
of ongoing trends, external perspectives from
agencies’ engagements with foreign counterparts
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NATIONAL CFT STRATEGY 2022
and national strategic interests and considerations.
Singapore’s participation in relevant international
and regional platforms further yields deeper
insights into emerging global and regional
typologies. This holistic approach allows us to
continue to evaluate and assess our TF threats and
vulnerabilities regularly, as well as prioritise these
risk areas, so as to promptly address them in a
coordinated fashion.
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Point 2: Strong Legal and Sanctions Frameworks
To support the global fight against terror, Singapore’s overarching CFT policy objective
is to ensure that terrorism is not financed from or through Singapore. This involves
detecting, deterring, and preventing TF-related activities, including those related to the
generation of funds, movement of funds and use of such funds to support terrorism
purposes, whether in Singapore or overseas.
for proportionate punishment and are sufficiently
effective at deterring TF-related offences.
Strategy in Action
2.1
To achieve our CFT policy objectives, we
have adopted the following frameworks:
2.2
A comprehensive legal framework is in
place to enable law enforcement agencies (LEAs)
to take swift and effective action against terrorists,
terrorist organisations and their supporters,
including financiers of terrorism. Key legislation
to combat TF include the Terrorism (Suppression
of Financing) Act 2002 (TSOFA) and the Internal
Security Act 1960 (ISA). These Acts are regularly
reviewed to ensure that they remain relevant and
effective. For example, Parliament approved
legislative enhancements to the TSOFA in 2018
which included raising the maximum penalty for
TF offences.2 This ensures that our laws provide
2
The key legislative enhancements to the TSOFA include:
Expanding the prohibition of TF activities to include the
financing of terrorism training.
• Raising the maximum penalty for TF offences (from $1
million to higher of $1 million or twice the value of the
offending property, service or transaction.)
• Raising the maximum penalties for not disclosing
information related to TF to the Police to up to $1
million or twice the value of the offending property.
• Raising the maximum penalties for disclosing
information that might compromise a TF investigation
•
2.3
A
targeted
financial
sanctions
framework, which automatically takes into
account new UN designations, and is in line with
the FATF standards, the United Nations Security
Council Resolutions (UNSCRs) and related
Conventions against terrorism and TF. 3 This is
supported by a clear policy framework to identify
and designate terrorists. The Inter-Ministry
Committee on Terrorist Designation (IMC-TD)
was established as the designated authority and is
the competent authority responsible for the
designation of terrorists, overseeing the
listing/delisting of terrorists, and coordinating the
freezing/unfreezing of terrorist funds and assets in
accordance with the relevant UNSCRs.
under section 10B(1) and (2) to a fine of $250,000
and/or five years’ imprisonment.
• Enhancing penalties to make a person who abets,
conspires or attempts to commit a TF offence under
sections 3, 4, 5 or 6 of the Act liable to the same
punishment as if the person had committed the offence
under the applicable section.
3
The FATF is the global standard setter on combatting
money laundering and the financing of terrorism and
proliferation of weapons of mass destruction.
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NATIONAL CFT STRATEGY 2022
Looking Ahead
2.4
These frameworks guide agencies’ actions
in their domains to achieve the overall CFT policy
objectives. Singapore ensures that the rules and
guidelines within these frameworks remain
relevant and effective against the ever-evolving
threat of terrorism and TF.
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Point 3: Robust Regulatory Regime and Risk Targeted Supervisory Framework
Singapore has implemented a robust AML/CFT regulatory framework as well as a strong
risk focused supervisory framework for financial institutions (FIs), designated nonfinancial businesses and professions (DNFBPs) and NPOs to:
(i)
manage the ML/TF risks arising from their activities,
(ii)
ensure that such risks are adequately mitigated, and
(iii) monitor and supervise these entities for compliance with their AML/CFT
requirements.
Supervisors adopt a risk-based approach, target their supervisory efforts at higher risk
entities, and take timely steps, in cooperation with STRO, Singapore’s Financial
Intelligence Units (FIUs) and LEAs, to share TF risk information with the industry.
Supervisors have also established contacts and mechanisms to cooperate and exchange
relevant supervisory information between themselves and the industry as necessary.
3.1
More specifically, respective sector supervisors have taken a range of actions to mitigate the TF risks
arising from their sectors’ activities. This includes the following:
(i)
Effective and comprehensive sectoral AML/CFT requirements that are aligned with the
FATF Standards and international best practices;
(ii)
Enhanced surveillance and supervisory activities that are focused on higher TF risk
areas/entities, including requiring remediation measures where weaknesses are found and taking
proportionate and dissuasive supervisory actions where breaches are noted; and
(iii)
Engaging the industry through targeted outreach and industry cooperation initiatives to raise
TF awareness.
3.2
Supervisors also regularly review the AML/CFT laws and the supervisory approach taken for their
respective sectors, to ensure that they remain relevant and effective. The outcomes and effectiveness of CFT
measures taken by supervisors are also monitored by the AML/CFT SC and the IAC.
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Strategy in Action
Effective
and
comprehensive
sectoral
AML/CFT requirements aligned with the
FATF standards and international best
practices
3.3
FIs 4 , DNFBPs and NPOs are subject to
sectoral AML/CFT requirements and guidelines
issued by supervisors on measures to mitigate
ML/TF risks. These include the need to identify
and verify the customers, beneficial owners and
beneficiaries (where relevant), perform ongoing
monitoring and regular customer due diligence
(CDD), including enhanced due diligence
measures for higher risk customers, conduct
screening to promote compliance with CFT
requirements, and file suspicious transaction
report/s (STR) to STRO promptly. The sectoral
AML/CFT requirements and guidelines are
regularly reviewed to ensure that they remain
relevant and effective in mitigating ML/TF risks
and are aligned with the FATF standards and
international best practices.
3.4
Sector supervisors are also attuned to
evolving risks and developments and have
responded proactively to mitigate TF risks. For
example, MAS introduced the Payment Services
Act 2019 (PS Act) in January 2020 and
corresponding AML/CFT requirements to address
the ML/TF risks arising from new payment
services, such as digital payment token (DPT)
services, given the inherent ML/TF risks posed by
such services.5 Further amendments to the PS Act
4
This would include digital payment token service providers
which MAS also regulates and supervises as FIs.
5 Given the nascent regulatory regime for the DPT sector and
higher inherent ML/TF risks, MAS has required CDD to be
conducted from the first dollar of all DPT transactions (i.e. there is
no threshold below which CDD is not required, including for
occasional transactions).
were passed in Parliament in January 2021 to
expand the definitions of DPT services and crossborder money transfer services, so as to better
mitigate ML/TF risks and align Singapore’s
regime for virtual asset service providers with the
FATF standards. 6 Similarly, to raise the
AML/CFT standards in the precious stones and
precious metals sector, the Precious Stones and
Precious Metals (Prevention of Money
Laundering and Terrorism Financing) Act came
into effect in April 2019 and empowered the
Ministry of Law (MinLaw) to supervise the
PSMD sector for ML/TF. The Anti-Money
Laundering/Countering
the Financing of
Terrorism Division (ACD), a new sector
supervisor established under MinLaw, subjects
the PSMD sector to a full suite of AML/CFT
requirements.
Enhanced surveillance and
activities targeting at-risk areas
supervisory
3.5
Sector supervisors take a risk-based
approach in supervising and monitoring the
sectors for compliance with AML/CFT
requirements. Enhanced and targeted supervisory
activities are also applied on sectors and entities
that are inherently more exposed to TF abuse. For
example, in conjunction with the TF NRA, MAS
commenced a thematic review of at-risk money
remittance, banking and payment sectors in 2021,
to examine the effectiveness of their CFT
processes and controls, including the use of more
advanced monitoring capabilities to detect and
trace fund flows linked to terrorist activities.
6
MAS also amended the respective AML/CFT Notices for banks,
merchant banks, finance companies, credit or charge card licenses
and capital market services licenses on 1 March 2022, to clarify
that MAS’ AML/CFT requirements (including the Travel Rule)
would apply when these entities provide a digital token service for
its customers.
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Following the TF thematic review, MAS will
develop a guidance paper on sound CFT practices
that all FIs, including DPTSPs, should review and
adopt.
3.6
Where CFT control weaknesses are found,
supervisors will take appropriate supervisory
actions and follow-up with the regulated entities
to ensure that remediation measures are taken in a
timely manner. Supervisors will not hesitate to
take firm actions against errant entities, including
the imposition of a range of supervisory measures
(e.g. warning or imposition of restrictive actions)
and financial penalties, where control weaknesses
or breaches of AML/CFT requirements are found.
3.7
In addition, sector supervisors, in
partnership with the FIs and LEAs, perform
monitoring and surveillance activities to proactively detect higher risk areas or entities. These
include the monitoring of public open-source
information on international and regional
terrorism and TF developments, and analysing
data obtained from statutory returns submitted by
the FIs/DNFBPs/NPOs, STRs and other available
data sources (e.g. surveys and transaction data), as
well as information from LEAs. For example, the
Commissioner of Charities (COC) has been
conducting periodic Sectoral Reviews since 2019,
identifying
charities
with
overseas
activities/expenditures in FATF high-risk
jurisdictions. These charities were reviewed to
ensure that the appropriate AML/CFT procedures
were in place. Higher risk charities that conduct
overseas activities have been progressively taking
steps to put in place formal AML/CFT policies
and procedures and furnish such documents for
the COC’s review.
Targeted TF outreach
cooperation initiatives
and
industry
3.8
Supervisors
conduct
outreach,
in
collaboration with relevant authorities, to keep
their sectors abreast of changes to key TF risks
and threats to Singapore. Targeted engagement
sessions are also held for the higher risk sectors.
For example, MAS conducted webinars and
engagement sessions for relevant financial subsectors, including banks, remittance agents and
DPTSPs, to educate the sub-sectors on AML/CFT
requirements and MAS’ supervisory expectations.
MAS also continues to work with financial
industry players through platforms such as the
AML/CFT Industry Partnership (ACIP) and the
Association of Banks in Singapore (ABS) to raise
industry ML/TF risk awareness. For instance,
following the release of the TF NRA, CAD and
experts shared Singapore’s TF cases and regional
TF risks at the ABS Financial Crime Seminar in
July 2021. MAS similarly works with the payment
and DPT sector to raise their ML/TF risk
awareness.
3.9
In addition, STRO provides red-flag
indicators to FIs, DNFBPs and NPOs to help them
identify ML/TF risks and report suspicious
transactions. STRO further conducts industry
outreach to share case studies to enable entities to
better detect and report suspicious transactions.
3.10 For the PSMD sector, ACD/MinLaw
conducts compliance reviews and inspections to
examine registered dealers’ compliance with
AML/CFT requirements and takes appropriate
supervisory actions on the lapses identified.
Registered dealers are required to address the
AML/CFT weaknesses highlighted on a timely
basis and firm actions will be taken against entities
which failed to take remediation measures. Since
April 2020, ACD/MinLaw regularly disseminates
findings on emerging typologies and red flag
indicators to relevant AML/CFT supervision, law
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NATIONAL CFT STRATEGY 2022
enforcement, policy and intelligence agencies.
Based on the understanding of TF risks relevant to
the PSMD sector, coupled with the findings from
the surveillance and monitoring of the
international, regional and domestic CFT situation
in relation to the PSMD sector, ACD/MinLaw
publishes updated red flag indicators to the sector.
ACD/MinLaw’s ongoing AML/CFT training for
the sector also contains up-to-date cases detected
from such findings.
Looking Ahead
Sector supervisors will continuously review
and take steps to strengthen the private sectors’
awareness of TF risks and CFT controls
through outreach, industry guidance and riskfocused supervision
3.11 These include engagement sessions to
enhance their understanding of TF risks that are
relevant to the respective sectors and issuance of
guidance on CFT requirements and best practices.
3.12 For example, as the regulatory regime for
DPTSPs is relatively new, MAS’ initial focus is
on raising the entities’ TF (and ML) risk
awareness and strengthening their controls. As
part of MAS’ upcoming supervision of DPTSPs,
MAS will also give attention to how DPTSPs
effectively implement their CFT controls taking
into account the risks of their activities. In
addition, MAS will continue to engage the
remittance, banking and other payment sectors on
TF developments and risks.
to TF exploitation and to recommend mitigating
measures which charities can adopt.
Sector supervisors will leverage data analytics
and technological tools to enhance surveillance
and supervisory activities
3.14 For closer scrutiny, MAS’ supervision of
FIs is complemented by data analytics to detect
and target higher risk activities and FIs involved.
Alongside traditional information sources such as
statutory returns and STRs, MAS will leverage
and explore the use of new technologies to draw
insights from data sources to enhance our
supervisory activities. For example, transactional
information on the public blockchain has allowed
MAS to pro-actively detect unlicensed DPT
activities for enforcement action and enhance its
assessment of ML/TF risks for licensed entities.
MAS has also worked closely with STRO to
enhance the reporting template used for suspicious
transaction reporting. The enhanced template is
more structured and machine readable, thus
enabling MAS to perform analysis and identify
networks of related STRs and identify systemic
threats in a more timely manner.
3.13 For the charity sector, the COC plans to
develop a TF risk mitigation toolkit to guide
charities to assess their organisation’s level of risk
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Point 4: Decisive Law Enforcement Actions
Singapore takes a serious view of anyone who supports, promotes, and/or makes
preparations to undertake or undertakes armed violence, regardless of how they
rationalise such violence or where the violence takes place. A zero-tolerance stance is taken
against any TF activity.
Our LEAs will not hesitate to take, and have taken, swift and effective actions against
terrorists, terrorist entities and their supporters, including financiers of terrorism.
Strategy in Action
4.1
All credible instances of TF are
investigated and pursued as a distinct criminal
activity. This includes, as necessary, commencing
(i) independent investigations into TF allegations
in the first instance, and (ii) parallel financial
investigations to support counter terrorism
investigations and/or identify further financial
networks and commonalities, if any.
4.2
Singapore has an effective operational
framework to investigate and prosecute TF cases.
The Counter-Financing of Terrorism Branch
(CFTB) of the CAD in Singapore Police Force is
the lead unit responsible for investigating TF in
Singapore and works closely with security and
other relevant agencies to take decisive
enforcement actions. Clear procedures and roles
are established among the relevant domestic
authorities.
4.3
As Singapore’s domestic security and
intelligence agency, ISD collects and analyses
intelligence in relation to all terrorism-related
activities, including the financing of terrorism. By
exchanging information with its foreign
counterparts and through its own investigations,
ISD contributes to the national effort by working
closely with CFTB and other relevant agencies to
share information and intelligence on TF matters.
There are established work processes and
communication channels to share information
with domestic agencies.
4.4
Financial intelligence is integral to the
detection and investigation of criminal activities,
including TF. STRO is responsible for receiving
and analysing STRs. To improve the quality of
TF-related STRs filed by reporting entities, STRO
conducts ongoing engagements with industry
partners, including at-risk sectors; and publishes
relevant and targeted guidance and red-flag
indicators on terrorism/TF. Such ongoing
engagements have led to a better general
understanding of TF typologies and risk indicators,
among the relevant stakeholders.
4.5
CFTB works closely with ISD and STRO
to ensure that all credible instances of TF,
including those arising from financial intelligence
are thoroughly investigated in Singapore. The
security and enforcement agencies exchange
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NATIONAL CFT STRATEGY 2022
intelligence and information and collaborate on
investigations; while STRO disseminates
financial intelligence relating to terrorism/TF to
the respective competent authorities to support
their operational needs. CFTB also works closely
with the Attorney-General’s Chambers (AGC) to
ensure that investigative efforts translate to
successful prosecutions. Since 2016, AGC has
prosecuted and secured convictions against 13
individuals for TF. In line with Singapore’s zerotolerance stance, lengthy imprisonment terms
have been sought for and successfully obtained
against the 13 individuals.7
4.6
Agencies
leverage
public-private
partnerships such as the CFT Operational Group,
set up under the ambit of ACIP, to enhance
operational efficiency and establish relevant
networks. 8 This workgroup provides a platform
for key stakeholders to share CFT-related trends
and in so doing, strengthens the understanding of
terrorism/TF risks within the different sectors. It
is a key operational platform for investigative
collaborations in priority TF cases round the clock.
The composition of the CFT Operational Group
takes into consideration the TF risk landscape
faced in Singapore and its key TF risks, and
includes relevant industry players, such as banks,
money remittance agents, payment service
providers, and government stakeholders.
continue to seek heavy and proportionate
sentences against convicted perpetrators that
commensurate with the severity of the offences to
serve as an effective deterrence against would-be
perpetrators. Authorities will also continue to
expand collaboration with the private sector,
including through ACIP, to ensure better
communication of risks to detect and disrupt TF
activities.
4.8
Where material TF risks are identified,
agencies will adopt a WOG approach and work
together to design and implement appropriate
preventive actions to close the gaps observed. For
instance, in order to reduce illicit Cross-Border
Cash Movements (CBCM) and unlicensed money
remittances, which have been identified as key TF
risk areas for Singapore, relevant agencies came
together to reinforce the operational frameworks
to mitigate these risks through robust detection
and investigation. We recognise the importance of
continuing such collaboration and will continue to
prioritise strengthening the cooperation amongst
domestic competent authorities as well as
stakeholders in the private sector. These interagency efforts as well as public-private
partnerships are continuously reviewed to ensure
that we remain capable of addressing emerging TF
threats.
Looking Ahead
4.7
CFTB, ISD and STRO will continue to
closely collaborate to ensure all instances of TF
are promptly detected and investigated. We will
7
Six individuals and four individuals were prosecuted and
convicted in 2016 and 2020 respectively. There was one
individual prosecuted and convicted for each of the years
2019, 2021 and 2022. The sentences meted out ranged from
18 months to 60 months.
8
ACIP is a private-public partnership established in April
2017 and is co-chaired by CAD and MAS. It brings together
the financial sector, regulators, LEAs and other government
entities to collaboratively identify, assess and mitigate key
and emerging ML/TF risks facing Singapore.
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Point 5: International Partnerships and Cooperation
Singapore’s connectivity as a major global financial centre and international transport
hub makes us vulnerable as a transit point for illicit proceeds to the region and other
foreign jurisdictions. Singapore recognises that the raising and moving of funds for
terrorists and terrorist activities overseas is a more pertinent TF threat for us, than the
financing of the same domestically. In line with our zero-tolerance stance against any TF
activities, regardless of where the violence is to take place, we view international
cooperation, both at the regional and global levels, as a key component of Singapore’s CFT
strategy to counter such threats.
Domestic authorities utilise a range of international cooperation mechanisms to achieve its
law enforcement objectives for TF matters. These include bilateral and multi-lateral
partnerships as well as leveraging structured international and regional platforms such as
INTERPOL, ASEANAPOL, the Egmont Group, ASEAN-MLAT, SEAJust and the CTF
Summit, to share intelligence, exchange information and conduct joint operations, where
appropriate.
Providing and seeking assistance to and from
other jurisdictions in criminal matters
Strategy in Action
5.1
Singapore’s efforts in international
cooperation for criminal matters can be broadly
considered from two dimensions. First, providing
assistance to other jurisdictions through formal
and informal channels spontaneously and on
request; and seeking assistance from other
jurisdictions. Second, rigorously implementing
and contributing to the development of the
international standards on combatting ML/TF/PF
set by the FATF and relevant UNSCRs. This is
done by participating in the relevant international
and regional platforms.
5.2
Singapore provides and seeks assistance to
and from other jurisdictions respectively relating
to criminal matters through both formal and
informal channels. Such assistance includes
formal requests for mutual legal assistance (MLA),
the exchange of information between local and
foreign LEAs, as well as the spontaneous
exchange of financial intelligence by STRO with
foreign FIUs.
5.3
TF offences are criminalised in Singapore
under the TSOFA, which was enacted to give
effect to the International Convention for the
Suppression of the Financing of Terrorism (FT
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Convention), to which Singapore is a party. The
main TF offences in TSOFA are listed in the
Second Schedule of the Mutual Assistance in
Criminal Matters Act (MACMA). Thus,
Singapore can provide the full suite of MLA for
these offences. Singapore is also party to the
ASEAN Treaty on Mutual Legal Assistance in
Criminal Matters (Among Like-Minded ASEAN
Member Countries) (ASEAN-MLAT), which was
adopted in 2004 and has since been ratified by all
ASEAN Member States. Given the increased level
of TF threats in the region, assistance rendered
through the ASEAN-MLAT is an important part
of Singapore’s CFT strategy. Specific to terrorism
and in addition to the FT Convention, Singapore
is also a party to the International Convention for
the Suppression of Terrorist Bombings and the
International Convention for the Suppression of
Acts of Nuclear Terrorism. As required under all
three treaties, Singapore is able to provide all
parties to the conventions with the greatest
measure of assistance in connection with criminal
proceedings in respect of offences set out under
each treaty.
5.4
TF offences under TSOFA are extraditable
offences in Singapore under section 33(1) TSOFA.
In addition, terrorist acts (e.g. murder, malicious
and wilfully wounding) are covered by the general
list of offences in the First Schedule of the
Extradition Act 1968. Singapore is thus able to
assist with extradition requests relating to TF
offences from any country which is a party to the
FT Convention.
Exchange of Information through FIUs
counterparts. Singapore has also introduced
legislative changes to broaden the exchange of
financial intelligence with more FIU counterparts.
Since 2019, following an amendment to the
Corruption, Drug Trafficking and Other Serious
Crimes (Confiscation of Benefits) Act 1992
(CDSA), STRO can exchange financial
intelligence with members of the Egmont Group
without the need for a Memorandum of
Understanding/Letter of Undertaking. This has
effectively tripled STRO’s network of FIU
counterparts with whom STRO can exchange
financial intelligence, including on TF.
Participating in international and regional
platforms
5.6
Singapore is an active participant in
international fora such as the FATF, the
Asia/Pacific Group on Money Laundering (APG),
the Southeast Asia Justice Network (SEAJust), the
Priority Counter-Terrorism Financing Forum –
Central Authorities (CTF Forum), and
INTERPOL’s Project PACIFIC Working Group.
In particular, Singapore has contributed to FATF
projects on TF and STRO is also a part of the
Counter-Terrorism Financing Summit, which
brings together FIUs in the ASEAN region,
Australia and New Zealand, to collaborate on
AML/CFT matters and develop regional solutions
to TF and high-risk financial crimes through
financial intelligence sharing.
5.7
Such fora allow Singapore to learn from
our regional and the international CFT community
and contribute to the development of international
standards in CFT.
5.5
To date, STRO has concluded a total of 51
Memoranda of Understanding/Letters of
Undertaking, which allow STRO to share
financial intelligence with these foreign
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Looking Ahead
Increased efforts in providing and seeking
assistance in criminal matters
5.8
Singapore endeavours to ensure that
requests for assistance from other jurisdictions
relating to criminal matters are duly considered
and executed, where possible, and in a timely
fashion. To complement assistance through
formal channels, Singapore will continue to
exchange information with their foreign
counterparts via informal channels and build close
relationships with them.
5.9
Singapore will also continue to leverage
informal channels of cooperation to proactively
tackle TF flows. This includes proactive
information sharing and, where appropriate,
coordinated enforcement action with our
international counterparts.
Continued participation in international and
regional platforms
5.10 Given the transnational nature of TF, it is
important to maintain a robust understanding of
TF risks, at both the international and regional
levels. Singapore will continue to actively
participate in international and regional platforms
to maintain and enhance international cooperation.
Singapore also seeks to tap on the expertise and
experiences of other jurisdictions, such as
Australia, US, UK, France, Malaysia and
Indonesia at the CTF Forum, to improve our CFT
efforts and build closer relationships between
jurisdictions to further strengthen global CFT
capabilities.
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NATIONAL CFT STRATEGY 2022
CONCLUDING REMARKS
Singapore maintains a watchful eye on events around the world. It is evident that the global threat of
terrorism, violent extremism and its financing remains a real and present danger, globally and domestically.
In recent years, while the global terrorism landscape has evolved to one that features more self-radicalised
individuals who may be self-funded and thereby only leave little or no traces in the financial system, it
remains true that terrorists and terrorist organisations need money to operate. Common sources of funding
would include donations from supporters (including involving the misuse of NPOs) and proceeds generated
from criminal activities. To disrupt their dangerous operations, we need to disrupt and prevent funds
(including virtual assets as seen from more recent typologies) from reaching the hands of terrorists and
terrorist entities.
For this reason, Singapore will not let up in our efforts to counter the financing of terrorism.
This five-point CFT strategy guides us in our continuous efforts to detect, deter and prevent TF, and is
complementary to Singapore’s counter terrorism strategy. We first ensure that we have a continued good
understanding of our TF threats and vulnerabilities; then we formulate the necessary frameworks to ensure
that we have an up-to-date and comprehensive structure that will support our policy objectives. This is
coupled with the implementation of robust AML/CFT regulatory and supervisory regimes for
FIs/DNFBPs/NPOs to ensure that the relevant sectors are not abused for TF purposes. Thereafter, we rely
on an efficient and effective law enforcement infrastructure that will take swift and resolute actions against
terrorists, terrorist entities and their supporters including financiers of terrorism. Finally, Singapore has
established strong working relationships with international counterparts to facilitate cooperation in the
countering of financing of terrorism, and ensure we are updated on TF typologies.
Singapore is strongly committed to taking firm and resolute action against TF to keep our country, region
and the world safe.
***** END *****
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NATIONAL CFT STRATEGY 2022
TABLE OF ACRONYMS
ABS
Association of Banks in Singapore
ACD
Anti-Money Laundering/Countering the Financing of Terrorism Division
ACIP
AML/CFT Industry Partnership
AGC
Attorney-General’s Chambers
AML/CFT
Anti-Money Laundering / Countering the Financing of Terrorism
APG
Asia/Pacific Group on Money Laundering
AQ
Al-Qaeda
ASEAN-MLAT
ASEAN Treaty on Mutual Legal Assistance in Criminal Matters (Among
Like-Minded ASEAN Member Countries)
CAD
Commercial Affairs Department
CBCM
Cross-Border Cash Movements
CDD
Customer Due Diligence
CFTB
Counter-Financing of Terrorism Branch (of CAD)
COC
Commissioner of Charities
CTF
Counter-Terrorism Financing
CTF Forum
Priority Counter-Terrorism Financing Forum – Central Authorities
DNFBPs
Designated Non Financial Businesses and Professions
DPT
Digital Payment Token
DPTSPs
Digital Payment Token Service Providers
FATF
Financial Action Task Force
FIs
Financial Institutions
FIU
Financial Intelligence Unit
IAC
Inter-Agency Committee
IMC-TD
Inter-Ministry Committee on Terrorist Designation
ISA
Internal Security Act
ISD
Internal Security Department
ISIS
Islamic State of Iraq and Syria
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NATIONAL CFT STRATEGY 2022
JI
Jemaah Islamiyah
LEAs
Law Enforcement Authorities
MACMA
Mutual Assistance in Criminal Matters Act
MAS
Monetary Authority of Singapore
MHA
Ministry of Home Affairs
MinLaw
Ministry of Law
ML
Money Laundering
MLA
Mutual Legal Assistance
MOF
Ministry of Finance
NPOs
Non-Profit Organisations
NRA
National Risk Assessment
PSMDs
Precious Stones and Metals Dealers
RSIS
S. Rajaratnam School of International Studies
RTIG
Risks and Typologies Inter-Agency Group
SC
Steering Committee
SEAJust
Southeast Asia Justice Network
STR
Suspicious Transaction Report
STRO
Suspicious Transaction Reporting Office
TF
Terrorism Financing
TSOFA
Terrorism (Suppression of Financing) Act
UN
United Nations
UNSCRs
United Nations Security Council Resolutions
WOG
Whole-of-Government
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