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SUSPICIOUS TRANSACTION REPORTING OFFICE (STRO)

STRO is Singapore’s Financial Intelligence Unit (FIU).  We receive Suspicious Transaction Reports (STRs) and other financial information such as Cash Movement Reports (CMRs) and Cash Transaction Reports (CTRs) and analyse them to detect Money Laundering, Terrorism Financing and other serious crimes. Where possible offences are detected, we disseminate the financial intelligence to relevant enforcement and regulatory agencies.
 
The STRO provides instructions to filers on filing STRs, CMRs and CTRs.  We also provide case studies and feedback to encourage filers to increase the quantity and quality of STRs.

The STRO represents Singapore at international forums and regional bodies in global Anti-Money Laundering/Counter-Financing of Terrorism efforts. We are a member of the Egmont Group of FIUs and we maintain close working relationships with the FIUs of other jurisdictions. 


Cash Transaction Reporting

Precious Stones and Precious Metals Dealers


 

Importance of Cash Transaction Reporting

Precious stones and precious metals have high commercial value and are portable. They are easy to convert to cash. Dealing in precious stones and precious metals is thus a convenient means for criminals (including terrorists) to launder their illicit funds.

There is a requirement for regulated dealers as defined under the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019 (PSPM Act) and pawnbrokers under the Pawnbrokers Act 2015 to report cash transactions. This is to facilitate the detection, investigation and prosecution of money laundering, terrorism financing and other serious crimes.

The cash transaction reporting regime is aligned with the international standards set by the Financial Action Task Force (FATF) to combat money laundering and the financing of terrorism and proliferation of weapons capable of causing mass destruction.


Reporting Requirement


Section 17 of the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019 (PSPM Act) and section 74A of the Pawnbrokers Act 2015 set out the cash transaction reporting regime for cash transactions in precious stone, precious metals, precious products and asset-backed tokens.

  1. Regulated Dealers
  2. If you are a regulated dealer under the PSPM Act, you are required to submit a Cash Transaction Report (CTR) to the Suspicious Transaction Reporting Office (STRO) and a copy separately to the Anti-Money Laundering/ Countering the Financing of Terrorism Division (ACD) when:

    1. You sell any precious stone(s), precious metal(s), precious product(s) (PSPM) or asset-backed token(s) to a customer and receive cash or cash equivalent exceeding SGD 20,000 as payment;

    2. You conduct two or more sales of any PSPM or asset-backed token(s) in a single day to the same customer, or to customers whom you know act on behalf of the same person and receive cash or cash equivalent in total exceeding SGD 20,000 as payment;

       

    3. You (as a secondhand goods dealer) purchase any PSPM from a customer (who is not a regulated dealer) and pay cash or cash equivalent exceeding SGD 20,000;

       

    4. You (as a secondhand goods dealer) make two or more purchases of any PSPM in a single day, from the same customer, or customers whom you know are acting on behalf of the same person (none of whom are regulated dealers) and pay cash or cash equivalent exceeding SGD 20,000;

       

    5. You redeem an asset-backed token(s) from a customer (who is not a regulated dealer) for cash or cash equivalent in total exceeding SGD 20,000; or

       

    6. You conduct two or more redemptions of any asset-backed token(s) in a single day from the same customer, or customers whom you know act on behalf of the same person (none of whom are regulated dealers), for cash or cash equivalent exceeding SGD 20,000.

    Any regulated dealer who fails to comply with the above requirement shall be guilty of an offence and shall be liable on conviction to a fine not exceeding SGD 20,000 and/or imprisonment for a term of up to two years.

    For more information, please refer to ACD's website.


  3. Pawnbrokers
  4. If you are a pawnbroker under the Pawnbrokers Act 2015, you are required to submit a Cash Transaction Report (CTR) to the Suspicious Transaction Reporting Office (STRO) and a copy separately to the Registry of Pawnbrokers (ROP) when:


    1. You sell any PSPM to a customer and receive cash or cash equivalent exceeding SGD 20,000 as payment; or

       

    2. You conduct two or more sales of any PSPM in a single day to the same customer, or to customers whom you know act on behalf of the same person and receive cash or cash equivalent in total exceeding SGD 20,000 as payment.

    Any pawnbroker who fails to comply with the above requirement shall be guilty of an offence and shall be liable on conviction to a fine not exceeding SGD 20,000 and/or imprisonment for a term of up to two years.

How to File a Cash Transaction Report

You can file a Cash Transaction Report (CTR) (Form NP 784) electronically via STRO Online Notices And Reporting platform (SONAR).

All completed CTRs must be submitted within 15 business days (Mondays – Fridays, excluding Saturdays, Sundays and Public Holidays) after the date of the transaction.


Download CTR and Instruction Guide
Forms

Form NP 7841
(file electronically via SONAR)2

Form Guide Guide to fill up Form NP 784

 

1To avoid encountering the following error message, please make sure to download the original Form NP 784 and open it using Adobe Acrobat Reader DC.

2 If you do not have a CorpPass account (which is required in order to file a Form NP 784 electronically on SONAR) and you wish to file a Form NP 784, you should download and complete the form in softcopy and print it out. Fields that are greyed out should be completed/handwritten and the form should be signed. Thereafter, you will need to mail the original signed copy to STRO and a copy to the ACD (if you are a regulated dealer) or ROP (if you are a pawnbroker).

The addresses are:
Head, Suspicious Transaction Reporting Office
Commercial Affairs Department
391 New Bridge Road #06-701
Police Cantonment Complex Block D
Singapore 088762

For regulated dealers:
Registrar of Regulated Dealers
Anti-Money Laundering/ Countering the Financing of Terrorism Division
Ministry of Law
45 Maxwell Road #07-11
The URA Centre (East Wing)
Singapore 069118

For pawnbrokers:
Registrar of Pawnbrokers
Registry of Pawnbrokers
Ministry of Law
45 Maxwell Road #07-11
The URA Centre (East Wing)
Singapore 069118

 

Regulated dealers and pawnbrokers are required to provide the Anti-Money Laundering/ Countering the Financing of Terrorism Division (ACD) or the Registry of Pawnbrokers (ROP) respectively with a copy of the CTR that you have filed with the Suspicious Transaction Reporting Office (STRO).

You will enjoy convenience by e-filing. When you e-file CTR via SONAR, you agree for STRO to extend a copy of your report to the ACD (for regulated dealers) or ROP (for pawnbrokers). Therefore, you need not separately mail your report to the ACD or ROP.

It is an offence under section 27 of the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019 and section 70 of the Pawnbrokers Act 2015 to provide any information that is materially false or misleading or to omit to provide any information knowing or having reason to believe that such omission will create a false or misleading impression.

Related Links

  1. FAQs on Cash Transaction Reporting Regime for Precious Stones and Metals Dealers (PSMDs)

  2. FAQs on Filing Requirements for a Cash Transaction Report for Regulated Dealers and Pawnbrokers

  3. About SONAR

  4. Anti-Money Laundering/ Countering the Financing of Terrorism Division (ACD) Webpage

  5. Registry of Pawnbrokers Webpage


CASINOS

Importance of Cash Transaction Reporting


Casinos are large cash-based businesses. The frequent use of cash makes casinos highly vulnerable to money laundering and terrorism financing. The requirement for casino operators to report cash transactions will therefore facilitate the detection, investigation and prosecution of money laundering, terrorism financing and other serious crimes.

There is a requirement for casino operators as defined under the Casino Control (Prevention of Money Laundering and Terrorism Financing) Regulations 2009 to report cash transactions. This is to facilitate the detection, investigation and prosecution of money laundering, terrorism financing and other serious crimes.

The cash transaction reporting regime for casino operators is aligned with the international standards set by the Financial Action Task Force (FATF) to combat money laundering and the financing of terrorism and proliferation of weapons capable of causing mass destruction.


Reporting Requirement


A casino is required to submit a Cash Transaction Report (CTR) to the Suspicious Transaction Reporting Office (STRO), before the end of the applicable reporting period, for:

  1. Every cash transaction with a patron involving either cash in or cash out of SGD 10,000 or more in a single transaction; or

  2. Multiple cash transactions which the casino operator knows are entered into by or on behalf of a patron, the aggregate of which is either cash in or cash out of SGD 10,000 or more in any gaming day.

Any casino operator which fails to comply with the above requirement shall be guilty of an offence and shall be liable on conviction to a fine not exceeding SGD 20,000.


How to File


Casino operators in Singapore submit casino Cash Transaction Reports (CTRs) online to the Suspicious Transaction Reporting Office (STRO).


Cross Border Cash Movement REPORTING

Importance of Cross Border Cash Movement Reporting

Criminals and terrorist financiers around the world have been known to use cash couriers as a means to physically move funds across borders, to finance their illicit activities or to launder their ill-gotten gains.

Since 1 November 2007, Singapore has imposed measures for the disclosure of information on movements of physical currency and bearer negotiable instruments (or CBNI) into and out of Singapore. The initiative is to facilitate the detection, investigation and prosecution of drug trafficking offences and serious crimes. This is consistent with international Anti-Money Laundering and Counter-Financing of Terrorism standards recommended by the Financial Action Task Force (FATF), an inter-governmental body that develops and promotes such policies. Singapore is a member of the FATF.

This initiative is not a currency control measure. There is no restriction on the type or amount of cash which is moved into or out of Singapore.

Reporting Requirement

If you move physical currency and bearer negotiable instruments (or CBNI) exceeding SGD 20,000 (the prescribed amount) or its equivalent in a foreign currency into or out of Singapore, you are required to make a Cash Movement Report. If you receive CBNI exceeding the prescribed amount from outside Singapore, you are required to give a report within five business days upon receipt.

Examples of Physical Currency and Bearer Negotiable Instruments

Exemptions

  • A commercial passenger carrier is not required to give a report in respect of CBNI in the possession of its passengers.
  • A commercial goods carrier is not required to give a report if the CBNI is carried on behalf of another person and the other person has not disclosed to the carrier that the goods carried include CBNI and the carrier does not know and has no reasonable ground to believe that the goods carried on behalf of the other person include CBNI.


Cash Movement Reports by Travellers

If you enter or leave Singapore and you (whether for yourself or on behalf of any other person, and whether together with other persons) carry physical currency and bearer negotiable instruments (or CBNI) exceeding the prescribed amount, you will need to complete the Physical Currency and Bearer Negotiable Instruments Report (Traveller) or Form NP 727.

You need to submit the Form NP 727 online within 72 hours before your arrival in or departure from Singapore i.e. before coming to an Immigration Checkpoint. 

Cash Movement Reports by Senders, Carriers or Recipients

If you move physical currency and bearer negotiable instruments (or CBNI) exceeding the prescribed amount into or out of Singapore, through cargo, post or other means, you will need to complete the Physical Currency and Bearer Negotiable Instruments Report (Sender, Carrier or Recipient) or the Form NP 728.

For a sender or carrier moving physical currency and bearer negotiable instruments (or CBNI) into or out of Singapore, you will need to submit the completed Form NP 728 to the Suspicious Transaction Reporting Office (STRO) no later than one business day before the moving of the CBNI. If it is not reasonably practicable to do so, you should submit the completed Form NP 728 to the STRO at the first opportunity and before the cash is moved.

If you receive CBNI exceeding the prescribed amount from outside Singapore, you are required to complete the Form NP 728 and submit it to the STRO within five business days upon receipt.

Punishment

A failure to give a full and accurate report is an offence under the Act. The punishment is a fine not exceeding SGD 50,000, or an imprisonment term not exceeding 3 years, or both. The cash may also be seized if the person fails to give the report.

The Commercial Affairs Department (CAD) investigates offences relating to this initiative and takes enforcement action against persons who did not give a full and accurate report.

How to File a Cash Movement Report

- For travellers entering or leaving Singapore on or after 13 May 2024, you can submit a Physical Currency and Bearer Negotiable Instruments Report (Traveller) or Form NP 727 online within 72 hours before your arrival in or departure from Singapore via:

  • ICA’s website

  • MyICA Mobile Application; or

  • After a successful submission of the Singapore Arrival Card (SGAC) on either ICA’s website or MyICA mobile application.
 

- For senders, carriers or recipients, you can file a CMR electronically via STRO Online Notices And Reporting platform (SONAR).

 

Download Form and Instruction Guide
Form NP 727
(Travellers)
Form NP 728
(Senders, Carriers or Recipients)

Forms
(in English)

Not applicable
Form NP 7282
(file electronically via SONAR)3
Form Guide
(in English)

Guide to Fill Up Form NP 7271

Guide to Fill Up Form NP 728

1This Form Guide is applicable for travellers entering or leaving Singapore on or after 13 May 2024.

2To avoid encountering the following error message, please make sure to download the original Form NP 728 and open it using Adobe Acrobat Reader DC.

If you do not have a SingPass or a CorpPass account (which is required in order to file a Form NP 728 electronically on SONAR) and you wish to file a Form NP 728, you should download and complete the form in softcopy, and print it out. Fields that are greyed out should be completed/handwritten and the form should be signed. Thereafter, you will need to deliver the form by post or by hand to the STRO’s office at:

Head, Suspicious Transaction Reporting Office
Commercial Affairs Department
391 New Bridge Road #06-701
Police Cantonment Complex Block D
Singapore 088762
Completed forms sent by post should reach STRO no later than two business days before the moving of the CBNI. 

Related Links


International Cooperation

Under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (CDSA) 1992, the Suspicious Transaction Reporting Office (STRO) is authorised to share information with a foreign Financial Intelligence Unit (FIU).

Membership In International Anti-Money Laundering And Counter-Financing Of Terrorism Organisations

Singapore is a member of several international Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) organisations. Membership in these organisations underscores Singapore's commitment to the fight against Money Laundering and Terrorism Financing.

Financial Action Task Force (FATF)

Singapore has been a member of the FATF since September 1991. The FATF (based in Paris) was set up to examine the problem and trends of money laundering activities. The FATF has issued a set of 40 Recommendations, currently used internationally to measure the effectiveness of a country's AML regime.
 
In June 2003, the FATF revised the 40 Recommendations and extended AML measures to designated non-financial businesses and professions such as casinos, real estate agents, dealers of precious metals/stones, accountants and lawyers.
 
In October 2001, the FATF issued its Eight Special Recommendations (SR) i.e. SR I to SR VIII on terrorism financing. These are aimed at denying terrorists and their supporters' access to the international financial system. In October 2004, the FATF issued a new SR i.e. SR IX on the use of cash couriers in terrorism financing activities. As a member of the FATF, Singapore must comply with both sets of recommendations.

Asia Pacific Group on Money Laundering (APG)

Singapore is a founding member of the Asia/Pacific Group on Money Laundering (APG). The APG is a FATF-style regional grouping for the Asia/Pacific region formed in 1997 to prevent and detect money laundering in the region. Singapore strongly supports the objectives and activities of the APG.

Egmont Group of FIUs

The STRO was admitted into the Egmont Group of Financial Intelligence Units (FIU) in June 2002. The Egmont Group of FIUs was established in June 1995 to provide an avenue for the timely sharing of information and provision of assistance between different jurisdictions. A FIU is the central, national agency responsible for receiving, analysing and disseminating financial intelligence to competent authorities. We have provided assistance to FIUs from various countries in the Egmont group over the years.


Partnership With the Community

Money launderers use financial instruments and facilities extensively to launder criminal proceeds. They target members of the financial community, such as banks, insurance companies, fund managers, money-changers and remittance companies as possible conduits for laundering money. They may mislead bona fide businesses and companies to assist to receive and pay out tainted monies or property related to terrorism. They may also draw in professionals such as lawyers and accountants to assist in the criminals' money laundering schemes.

We are mindful of the vulnerability of certain sectors and professions to money laundering.  To build a robust Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) regime in Singapore, we engage these sectors and professions to forge strong partnership to collect financial intelligence. 

Guidance on Filing STRs, CMRs and CTRs

The Suspicious Transaction Reporting Office (STRO) engages the financial institution sectors and the designated non-financial businesses and professions sectors, using both face to face channels and publications, to raise the usefulness of information in Suspicious Transaction Reports (STRs), Cross border cash Movement Reports (CMRs) and Cash Transaction Reports (CTRs) filed by them.

The STRO jointly organizes, with industry associations and regulators, closed-door dialogue sessions, seminars and conferences for financial institution sectors and designated non-financial businesses sectors and professions. STRO provides guidance on trends and typologies of crime relevant to the respective sectors and discuss issues that the sectors may have relating to AML/CFT at such events.

The STRO has also developed publications to provide suspicious indicators, case studies and trends detected from our analysis of STRs. Such publications are disseminated to financial institution sectors and designated non-financial businesses and professions sectors via the STRO Online Notices And Reporting platform (SONAR) and through the respective industry associations and regulators.


Statistics

Financial Intelligence

The Suspicious Transaction Reporting Office (STRO) receives, analyses and disseminates financial intelligence collated from Suspicious Transaction Reports (STRs), Cash Movement Reports (CMRs) and Cash Transaction Reports (CTRs). These reports play a pivotal role in the Anti-Money Laundering/Counter-Financing of Terrorism (AML/CFT) regime in Singapore. Over the years, there has been a significant increase in the number of STRs, CMRs and CTRs received. This is the result of continued vigilance of the reporting entities in detecting suspicious transactions and greater AML/CFT awareness in Singapore.

International Cooperation

STRO is a member of the Egmont Group of Financial Intelligence Units (FIUs) and we have collaborations with the international network of foreign FIUs to combat money laundering and terrorism financing. The STRO renders assistance to our foreign counterparts in response to their requests for assistance (RFA). The STRO also sends RFAs to our foreign counterparts to further our analysis of financial intelligence and provide investigation leads to domestic law enforcement agencies.

Community Partnership

STRO organizes meetings and discussion forums to share crime trends and typologies with the financial and business community, industry associations and domestic law enforcement agencies. Such engagements have been effective in enhancing the quantity and quality of financial intelligence received by STRO and the use of financial intelligence to fight crime.


Suspicious Transaction Reporting

Importance of Filing Suspicious Transaction Reports (STRs)

Money laundering is an international concern. Criminals are known to launder proceeds of crime to legitimize their ill-gotten gains. If they are not stopped, they can enjoy their fruits of crime with impunity.

In recent years, many parts of the world have seen terrorist attacks. Governments worldwide have responded by stepping up their efforts to counter acts of terrorism and the financing of terrorism.

Suspicious Transaction Reports (STR) play an important role in combating money laundering and terrorism financing. A high level of suspicious transaction reporting is an internationally accepted indicator of the existence of a strong Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) regime.

Since the establishment of the Suspicious Transaction Reporting Office (STRO) in January 2000, the number of STRs received by the STRO has risen steadily over the years. These STRs have been helpful in the detection of a number of significant cases.

Reporting Requirements

In the course of your trade, profession, business or employment, if you know or have reasonable grounds to suspect that any property may be connected to a criminal activity, you are required to file a Suspicious Transaction Report (STR) to the Suspicious Transaction Reporting Office (STRO). Failure to file a STR may constitute a criminal offence.

This reporting requirement is set out in Section 45 of the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 (also commonly known as CDSA).

Every person in Singapore and every Singapore citizen outside Singapore also have a duty to provide information on property and financial transactions belonging to terrorist and acts of terrorism financing to the Police. This legal obligation is set out in Sections 8 and 10 of the Terrorism (Suppression of Financing) Act 2002 (TSOFA). Failure to provide information may constitute a criminal offence.

The disclosure of terrorism financing information can be made to the Suspicious Transaction Reporting Office (STRO) in a STR.

How to File

You must file a Suspicious Transaction Report (STR) electronically via STRO Online Notices And Reporting platform (SONAR).

Download Form and Instruction Guide
 Form

STR Form

(file electronically via SONAR)

 
Form Guide  Guide to fill up STR Form

 

The regulators for a number of reporting industries require entities to comply with the Anti Money Laundering and Counter Financing of Terrorism (AML/CFT) legislation and regulations. They have requirements on customer due diligence, record keeping, internal controls, training and suspicious transaction reporting and have issued the industry specific guidelines and indicators on the detection and reporting of STRs.

Reporting Industry Indicators Directives and Guidelines
Approved CIS Trustees Indicators provided by Regulator MAS Notice SFA13-NO1/ Guidelines to MAS Notice SFA13-NO1
Website:https://www.mas.gov.sg
Bank Indicators provided by Regulator For Commercial Banks:
MAS Notice 626 / Guidelines to MAS Notice 626
Website:https://www.mas.gov.sg

For Merchant Banks:
MAS Notice 1014 / Guidelines to MAS Notice 1014
Website:https://www.mas.gov.sg
Casino Operator Available on SONAR Casino Control (Prevention of Money Laundering and Terrorism Financing) Regulations 2009
Direct Life Insurance Indicators provided by Regulator MAS Notice 314/ Guidelines to MAS Notice 314
Website:https://www.mas.gov.sg
Estate Agent/Developer
(Real Estate)
Indicators (Estate Agent) provided by Regulator

Indicators (Developer) provided by your Regulator
For Estate Agent:
Website:https://www.cea.gov.sg

For Developer:
Website:https://www.ura.gov.sg
Filing Agent/Qualified Individual
(Corporate Service Providers)
Indicators provided by Regulator Accounting and Corporate Regulatory Authority's directives on compliance with AML/CFT laws, regulations and guidelines.
Website:https://www.acra.gov.sg
Finance Company Indicators provided by Regulator MAS Notice 824 / Guidelines to MAS Notice 824
Website:https://www.mas.gov.sg
Financial Advisor Indicators provided by Regulator MAS Notice FAA-N06 / Guidelines to MAS Notice FAA-N06
Website:https://www.mas.gov.sg
Law Practice/Legal Practitioner Indicators provided by Regulator Website:https://www.lawsociety.org.sg
Licensed Trust Company/Trust Business Indicators provided by Regulator MAS Notice TCA-N03 / Guidelines to MAS Notice TCA-N03
Website:https://www.mas.gov.sg
Moneylender Indicators provided by Regulator Licence Conditions and AML/CFT laws
Website:https://www.mlaw.gov.sg; see section, “Information for Moneylenders”.
Money Changing and Remittance Business Indicators provided by Regulator MAS Notice 3001 / Guidelines to MAS Notice 3001
Website:https://www.mas.gov.sg
Non-Bank Credit Card or Charge Card Indicators provided by Regulator MAS Notice 626A / Guidelines to MAS Notice 626A
Website:https://www.mas.gov.sg
Non-profit/Not-for-profit Organisation Indicators provided by Regulator For Registered Charity:
Website:https://www.charities.gov.sg/

For Registered Society:
Website:https://www.ros.mha.gov.sg

For Mosque:
Majlis Ugama Islam Singapura policy documents on compliance with AML/CFT laws, regulations and guidelines
Pawnbroker Indicators provided by Regulator Licence Conditions and AML/CFT laws
Website:https://www.mlaw.gov.sg; see section, “Information for Pawnbrokers”.
Payment and Settlement System Indicators provided by Regulator MAS Notice PSOA-N02 / Guidelines to MAS Notice PSOA-N02
Website:https://www.mas.gov.sg
Precious Stones and Metals Dealer (PSMD) Indicators provided by Regulator Website:https://acd.mlaw.gov.sg
Professional Accountant / Auditor Indicators provided by Regulator Institute of Singapore Chartered Accountants' (ISCA) directives on compliance with AML/CFT laws, regulations and guidelines.
Website:https://www.isca.org.sg
Securities, Futures and Fund Management Indicators provided by Regulator For Capital Market Intermediaries:
MAS Notice SFA04-N02 / Guidelines to MAS Notice SFA04-N02

For Depositories:
MAS Notice SFA03AA-N01 / Guidelines to MAS Notice SFA03AA-N01
Website:https://www.mas.gov.sg
Trade (Zero GST Rated licensed Warehouses) Indicators provided by Regulator Singapore Customs' directives
Website:https://www.customs.gov.sg/businesses/customs-schemes-licences-framework/zero-gst-warehouse-scheme

 

Related Links


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