2024 Singapore National Strategy for Countering the Financing of Terrorism

Singapore has revamped its National Strategy for Countering the Financing of Terrorism (CFT), aiming to create a robust shield against the evolving threats of terrorism financing. The strategy emphasises a proactive, multi-pronged approach that combines stringent regulations, vigilant supervision, and decisive enforcement.

The Singaporean government’s five-pronged approach to countering the financing of terrorism (CFT) includes the following strategies, actions taken, updates, and future plans:

1. Coordinated and Comprehensive Risk Identification

Strategy in Action: The Singaporean government employs a whole-of-government approach to combatting money laundering, terrorism financing, and proliferation financing. The Risks and Typologies Inter-Agency Group (RTIG), comprising various agencies, oversees the identification, assessment, and mitigation of these financial risks. The government also partners with the private sector, academia, and foreign entities to enhance its understanding of terrorism financing risks.

Updates Since 2020: In 2024, Singapore conducted a survey to gain insights into its terrorism financing risks from the perspectives of other jurisdictions. The government also organized an industry consultation session with key financial institutions to discuss the latest terrorism financing typologies and threats. Additionally, a benchmarking exercise was conducted on the national CFT strategies of other jurisdictions to enhance the effectiveness of Singapore’s own strategy.

Looking Ahead: Singapore remains committed to participating in international and regional platforms to gain insights into emerging terrorism financing typologies and proactively evaluate and assess its key threats and vulnerabilities.

2. Strong Legal and Sanctions Frameworks

Strategy in Action: Singapore has established a comprehensive legal framework that empowers law enforcement agencies to combat terrorism financing activities effectively. Key legislation includes the Terrorism (Suppression of Financing) Act 2002 (TSOFA) and the Internal Security Act 1960 (ISA). The country also has a targeted financial sanctions framework that automatically implements new UN designations. The Inter-Ministry Committee on Terrorist Designation (IMC-TD) is responsible for designating terrorists and overseeing the freezing of terrorist funds and assets.

Updates Since 2020: The Corruption, Drug Trafficking, and Other Serious Crimes (Confiscation of Benefits) Act 1992 (CDSA) was amended in May 2023 to hold individuals criminally liable for allowing their payment accounts or Singpass accounts to be used for criminal activities. The Online Criminal Harms Act (OCHA) was enacted in July 2023, empowering the government to issue directives to online service providers to prevent activities suspected of involvement in criminal acts.

Looking Ahead: Singapore will continue to update its legal and financial sanctions frameworks to ensure their effectiveness in countering the financing of terrorism. The government is committed to providing law enforcement agencies with the necessary tools to tackle new challenges arising from the evolving threats of terrorism and its financing.

3. Robust Regulatory Regime and Risk-Targeted Supervisory Framework

Strategy in Action: Singapore has a robust regulatory and supervisory framework for financial institutions, designated non-financial businesses and professions (DNFBPs), and non-profit organizations (NPOs). Supervisors adopt a risk-based approach, targeting higher-risk entities and closely cooperating with the Suspicious Transaction Reporting Office (STRO) and law enforcement agencies to share information.

Updates Since 2020: The Payment Services (PS) Act 2019 was introduced in January 2020, along with corresponding AML/CFT requirements. Further amendments were passed in January 2021 to broaden the definitions of digital payment token (DPT) services and cross-border money transfer services. The Precious Stones and Precious Metals (Prevention of Money Laundering and Terrorism Financing) Act (PSPM Act) came into effect in April 2019, empowering the Ministry of Law to supervise the precious stones and precious metals dealers (PSMDs) sector for money laundering and terrorism financing risks. Amendments were made to the subsidiary legislation of the PSPM Act in November 2023 to require PSMDs to conduct customer due diligence measures for transactions involving payment received in DPT above SGD 20,000. The supervisory regime for the casino sector will be tightened in 2024, with the Gambling Regulatory Authority reducing the threshold for customer due diligence measures to SGD 4,000 for all financial transactions.

Looking Ahead: Sector supervisors will continue to assess and reinforce the private sector’s awareness of terrorism financing risks and controls through outreach, industry guidance, and risk-focused supervision. They will also harness data analytics and technological tools to bolster surveillance and supervision efforts.

4. Decisive Law Enforcement Actions

Strategy in Action: Singapore maintains a zero-tolerance policy towards terrorism financing. All credible instances undergo thorough investigation. The Counter-Financing of Terrorism Branch (CFTB) within the Commercial Affairs Department (CAD) of the Singapore Police Force leads these investigations. The Internal Security Department (ISD) collects and analyses intelligence concerning terrorism-related activities, including terrorism financing. The Suspicious Transaction Reporting Office (STRO) receives and analyses suspicious transaction reports.

Updates Since 2020: To address increasingly sophisticated cross-border cash movement activities, the Immigration and Checkpoint Authority (ICA) and CAD have strengthened detection and enforcement capabilities. The electronic Cross-Border Cash Reporting Regime (e-CBCRR) declaration form was introduced in May 2024. Agencies also utilize public-private partnerships, such as the CFT Operational Group, to enhance operational efficiency and detect terrorism/terrorism financing networks.

Looking Ahead: The CFTB, ISD, and STRO will maintain close collaboration to investigate and disrupt instances of terrorism financing. They will continue to take strong enforcement actions and expand collaboration with the private sector. Where significant risks are identified, agencies will collaborate to devise and execute suitable measures to address the
gaps.

5. International Partnerships and Cooperation

Strategy in Action: Singapore adopts a two-pronged approach to international cooperation. First, it assists other jurisdictions through formal and informal channels and seeks assistance when necessary. Second, it implements and contributes to developing international standards on combatting money laundering/terrorism financing/proliferation financing. Singapore actively participates in key international forums, such as the FATF, APG, SEAJust, CTF Forum, and INTERPOL’s Project PACIFIC Working Group. It also leverages both formal and informal channels to advance its CFT efforts, including mutual legal assistance requests, information exchange, and spontaneous exchange of financial intelligence.

Updates Since 2020: Singapore made terrorism financing a priority during its FATF Presidency from 2022 to 2024, championing various projects related to combating the financing of terrorism. The STRO is a member of the Financial Intelligence Consultative Group (FICG), which facilitates collaboration on AML/CFT matters and the development of regional solutions.

Looking Ahead: Singapore is committed to fully considering and executing requests for assistance from foreign jurisdictions related to terrorism and terrorism financing matters. It will continue to exchange information, conduct coordinated enforcement actions, and strengthen partnerships with international counterparts. The country is also committed to enhancing the understanding of emerging terrorism financing risks at both international and regional levels through active participation in various platforms.

Ingenia Consultants Pte. Ltd. is supporting financial institutions in their compliance, including anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”). Moreover, our internal audit services provide the board of directors and senior management with assurance regarding these obligations. Reach out to us to learn more about our regulatory support.
For any further information, please contact:
Adib Fajar
Associate
Ingenia Consultants Pte. Ltd.
adib.fajar@ingenia-consultants.com