The Singapore sanctions impose export controls on items that might be used as weapons or contribute to offensive cyber operations.  These items include technology and software that may have a military use, beyond just a commercial purpose.  There will be no permitted export of military goods, or of any and all items in the Electronics, Computers and Telecoms and Information Security categories of the Dual-Use Goods List of the Strategic Goods (Control) Order 2021.  There are also financial measures applicable to all financial institutions in Singapore.  Interestingly, the sanctions specifically mention financial transactions which involve cryptocurrency will also be covered.

The full list of specific measures is available here, and we expect that further directions from the Monetary Authority of Singapore will follow.

Next steps

Our recommendation is for clients (particularly, financial institutions, technology and energy companies in Singapore) to evaluate their risk-profile. 

Transactions relating to Russia particularly in USD through the US financial system, on items that might be used as weapons (cyber, land, air or sea) by Russia in Ukraine will be extremely high-risk, and to sanctioned entities or their affiliates will be prohibited (remembering to contemplate not just Singapore’s recent sanctions but also the sanctions regimes of other applicable jurisdictions (e.g. U.S., EU, UK) commensurate with your business profile). 

We can guide you on the Singapore Strategic Goods (Control) Order 2021 and compliance of your transactions.  We highlight the ESG (environmental, social and governance) component of these measures; do not readily dismiss the consumer interest in your business’ Russia profile and the reputational risk of persisting with certain transactions or matters at this time.

Authored by Stephanie Keen, Nick Williams, Ben Kostrzewa, Khushaal Ved, and Nicole Lim.