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MAS updates its Targeted Financial Sanctions page to include Russian sanctions

Here’s the new section:

Financial measures in relation to Russia

In response to Russia’s invasion of Ukraine, the Singapore Government has imposed financial measures targeted at designated Russian banks, entities and activities in Russia, and fund-raising activities benefiting the Russian government. These measures apply to all financial institutions in Singapore, including banks, finance companies, insurers, capital markets intermediaries, securities exchanges, and payment service providers. Digital payment token service providers are therefore specifically prohibited from facilitating transactions that could aid the circumvention of the financial measures. Details of these financial measures can be found in these Notices:

  • Notice SNR-N01 Financial Measures in Relation to Russia [Link] (183.1 KB)
  • Notice SNR-N02 Financial Measures in Relation to Russia – Non-prohibited Payments and Transactions [Link] (132.9 KB)

Here’s the meat of SNR-N01:

3 PROHIBITION AGAINST DEALING WITH, AND FREEZING OF ASSETS OF, DESIGNATED BANKS AND DESIGNATED ENTITIES
3.1 A financial institution must not, directly or indirectly (including through any provider of any brokering or other intermediary services) –
(a) establish business relations with or undertake any financial transaction for;
(b) enter into any financial transaction with;
(c) provide, or facilitate or procure the provision of, any financial assistance or service
(including but not limited to the granting of export credits, guarantees, insurance
or re-insurance) to; or
(d) transfer any financial assets or resources, or other assets or resources, to,
any Designated Bank or Designated Entity.
3.2 A financial institution that has in its possession, custody or control in Singapore, any funds, financial assets or economic resources owned or controlled, directly or indirectly, by a Designated Bank or a Designated Entity must:
(a) immediately freeze all such funds, financial assets or economic resources, as the case may be; and
(b) ensure that such funds, financial assets or economic resources are not made available, whether directly or indirectly, to or for the benefit of a Designated Bank or Designated Entity.

4 PROHIBITION AGAINST ENTERING INTO FINANCIAL TRANSACTIONS OR PROVIDING FINANCIAL ASSISTANCE OR SERVICES, ETC., IN RELATION TO THE DELIVERY OF CERTAIN ITEMS
A financial institution must not, directly or indirectly (including through any provider of any brokering or other intermediary services) –
(a) enter into any financial transaction with;
(b) provide, or facilitate or procure the provision of, any financial assistance or service
(including but not limited to the granting of export credits, guarantees, insurance
or re-insurance) to; or
(c) transfer any financial assets or resources, or other assets or resources, to,
any person, if the activity in (a), (b) or (c) relates to the export from, transhipment in or transit through, Singapore or any other jurisdiction to Russia of:
(i) any item specified in any Category Code in the List of Military Goods set out in Division 2 of Part 1 of the Schedule to the Strategic Goods (Control) Order 2021; or
(ii) any item specified in any Category Code under Category 3 (Electronics), Category 4 (Computers) or Category 5 (Telecommunications and “Information Security”) in the List of Dual-Use Goods in Division 2 of Part 2 of the Schedule to the Strategic Goods (Control) Order 2021.

5 PROHIBITION AGAINST ENTERING INTO FINANCIAL TRANSACTIONS OR PROVIDING FINANCIAL ASSISTANCE OR SERVICES, ETC., IN RELATION TO THE RAISING OF NEW FUNDS FOR THE RUSSIAN GOVERNMENT AND THE CENTRAL BANK OF THE RUSSIAN FEDERATION
5.1 A financial institution must not, directly or indirectly, purchase, sell, provide financial services for or assist in the issuance of, or otherwise deal with, securities or certificates of deposit issued by any person on or after 14 March 2022.
5.2 A financial institution must not, directly or indirectly, make or be part of any arrangement to make any new loans or credit to any person on or after 14 March 2022.
5.3 Paragraph 5.2 shall not apply to loans or credit that have a specific and documented objective of making funds available for trade which does not involve the export from, transhipment in or transit through, Singapore or any other jurisdiction to Russia of any item in (i) or (ii) of paragraph 4.
5.4 For the purposes of paragraphs 5.1 and 5.2, a “person” means:
(a) the Russian government;
(b) the Central Bank of the Russian Federation; or

(c) a legal person or legal arrangement that is owned or controlled by, directly or indirectly, or acts on behalf of or under the direction of (a) or (b).
6 PROHIBITION AGAINST ENTERING INTO FINANCIAL TRANSACTIONS OR PROVIDING FINANCIAL ASSISTANCE OR SERVICES, ETC., IN RELATION TO THE BREAKAWAY REGIONS OF DONETSK AND LUHANSK
6.1 A financial institution must not, directly or indirectly (including through any provider of any brokering or other intermediary services) –
(a) enter into any financial transaction with;
(b) provide, or facilitate or procure the provision of, any financial assistance or service
(including but not limited to the granting of export credits, guarantees, insurance
or re-insurance) to; or
(c) transfer any financial assets or resources, or other assets or resources, to,
any person in relation to any activity, including any sale, transfer or export of goods or technology, relating to any of the specific sectors in Donetsk or Luhansk.
6.2 For the purposes of paragraph 6.1, the “specific sectors” are:
(a) transport;
(b) telecommunications;
(c) energy; and
(d) prospecting, exploration and production of oil, gas and mineral resources.

7 PROHIBITION AGAINST DIGITAL PAYMENT TOKEN TRANSACTIONS
7.1 A financial institution must not enter into or facilitate any digital payment token transaction where the proceeds or benefits from such transaction may be used to facilitate any of the transactions or activities prohibited in paragraphs 3 to 6 (“prohibited digital payment token transaction”).
7.2 For the purposes of paragraph 7.1, entering into or facilitating a prohibited digital payment token transaction includes but is not limited to:
(a) offering the purchase, sale or exchange of digital payment tokens;
(b) brokering transactions between counterparties on digital payment tokens;
(c) offering or arranging financing for digital payment token transactions;
(d) offering the borrowing or lending of digital payment tokens; and
(e) making or arranging any primary and secondary market offerings of digital
payment tokens that make available the services referred to in (a), (b), (c) or (d) to other persons.

And what’s permitted, from SNR-N02:

3 PAYMENTS FOR BASIC EXPENSES AND REASONABLE FEES FOR CERTAIN SERVICES
Paragraph 3 of the Financial Measures Notice shall not apply to a financial institution1 in relation to the processing or facilitating of any payment or transfer of funds, financial assets or economic resources, where such payment or transfer is:
(a) necessary for the payment of basic expenses of any Designated Bank or Designated Entity, including (i) insurance premiums, (ii) reasonable fees for the provision of property management services or technology-related services, (iii) remuneration, allowances or Central Provident Fund contributions of employees, (iv) tax, (v) rent or storage services, (vi) mortgage payments, (vii) utility or telecommunication charges, and (viii) expenses that are necessary for the Designated Bank’s or the Designated Entity’s (as the case may be) compliance with its regulatory requirements; or
(b) exclusively for the payment of —
(i) fees or service charges imposed for the routine holding or maintenance of
frozen funds, financial assets or economic resources; or
(ii) reasonable professional fees and associated expenses for the provision of
audit, tax, legal or payroll services.
4 SPECIFIED TRANSACTIONS
4.1 Paragraph 3 of the Financial Measures Notice shall not apply to a financial institution in relation to specified transactions involving one or more of the Designated Banks.
4.2 For the purposes of paragraph 4.1, the “specified transactions”2 are:
(a) any transaction to facilitate a person’s withdrawal of funds, financial assets or economic resources pursuant to the termination of existing business relations between the person and the Designated Bank, for the benefit of the person, where such person is not a Designated Bank; and
(b) any transaction in relation to any funds, financial assets or economic resources which are necessary for the performance of the functions of the Embassy of the Russian Federation in Singapore.

Link:

MAS Targeted Financial Sanctions page

Notice SNR-N01, SNR-N02

Categories: MAS Updates Russia sanctions

eric9to5

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