28 October 2022
On 7 October 2022, the Monetary Authority of Singapore (“MAS”), Ministry of Home Affairs and Ministry of Finance published the National Strategy for Countering the Financing of Terrorism (“Strategy”), providing a roadmap for the development of future action plans to combat terrorism financing (“TF”). The Strategy spells out a five-pronged strategy to prevent, detect, investigate and enforce against TF.
The Strategy was formulated based on findings from a holistic assessment of TF risks conducted in 2020. In a press release announcing the publication of the Strategy, the authorities said that Singapore’s key TF threats are posed by regional and international terrorist groups as well as radicalised individuals, as they raise, move and use financial resources for terrorism purposes. Payment service providers carrying out cross-border money transfers and banks are inherently more vulnerable to TF threats, given the relative ease and speed with which their services may be used, coupled with Singapore being a financial and transport hub and its proximity to countries exposed to terrorism activities.
The five-pronged strategy comprises:
- coordinated and comprehensive risk identification;
- strong legal and sanctions frameworks;
- robust regulatory regime and risk targeted supervisory framework;
- decisive law enforcement actions; and
- international partnerships and cooperation.
Coordinated and comprehensive risk identification
The Strategy states that Singapore adopts a whole-of-Government approach to combatting money laundering, TF and proliferation financing. Agencies work together to review the TF landscape regularly, taking into account current typologies and international standards and requirements set by international bodies such as the Financial Action Task Force (“FATF”) and the United
Strong legal and sanctions frameworks
Singapore has adopted a comprehensive legal framework to enable law enforcement agencies to take swift and effective action against terrorists, terrorist organisations and their supporters, including financiers of terrorism. Key pieces of legislation include the Terrorism (Suppression of Financing) Act 2002 and the Internal Security Act 1960, which are regularly reviewed.
Singapore has also adopted a targeted financial sanctions framework, which automatically takes into account new UN designations, and is in line with the FATF standards, the UN Security Council Resolutions and relevant Conventions.
Robust regulatory regime and risk targeted supervisory framework
The Strategy highlights efforts to:
- ensure that Singapore’s anti-money laundering/countering the financing of terrorism (“CFT”) regulatory framework remains robust, and that Singapore’s risk focused supervisory framework is effective and aligned with international standards and best practices;
- further strengthen the private sector’s awareness of TF risks and CFT controls; and
- enhance surveillance and supervisory measures using data analytics and technological tools to draw insights from data sources, and to detect and target higher risk activities and entities.
Decisive law enforcement actions
The Strategy also outlines the Singapore Government’s efforts to:
- strengthen inter-agency collaboration to ensure all instances of TF are promptly detected and investigated;
- expand collaboration with private sector to better detect and disrupt TF activities; and
- ensure that investigative efforts translate into successful prosecutions through an effective legal operational framework.
International partnerships and cooperation
The Strategy states that international cooperation is a key component of Singapore’s CFT strategy to tackle TF threats. Domestic authorities utilise a range of mechanisms to achieve their law enforcement objectives for TF matters, including entering into bilateral and multi-lateral partnerships and leveraging on structured platforms to share intelligence, exchange information and conduct joint operations.
The following materials are available on the MAS website www.mas.gov.sg: