5 Compliance Requirements for Regulated Dealers in Singapore

Operating as a Regulated Dealer in Singapore — specifically for Precious Stones and Precious Metals Dealers (PSMDs)—comes with strict regulatory obligations under the Ministry of Law (MinLaw). As global efforts to combat money laundering intensify, paper-based compliance is no longer enough.

Criminals frequently target high-value goods like diamonds, gold, and luxury watches to launder illicit funds. To mitigate this, Singapore has established a robust regulatory framework. Whether you are a jeweler, a bullion dealer, or an auctioneer, failing to adhere to these rules can result in heavy fines, license revocation, or criminal prosecution.

To help you navigate these obligations, Alder Compliance has outlined the five essential compliance requirements every Regulated Dealer must implement to stay on the right side of the law.

1. Mandatory Registration with MinLaw

Before conducting any business involving precious stones, precious metals, or precious products (PSPM), you must be registered as a Regulated Dealer with the Ministry of Law. Operating without a valid license is a criminal offense. Furthermore, dealers must ensure that their registration details are kept up to date—any changes to directorship, business address, or ownership must be reported to the Registrar promptly.

2. Implementing a Robust AML/CFT Framework

You cannot rely on ad-hoc checks. Regulated Dealers are required by law to have internal policies, procedures, and controls (IPPCs) to combat money laundering and terrorism financing. This isn’t just about having a manual on a shelf; your framework must include a documented enterprise-wide risk assessment (EWRA) that identifies the specific vulnerabilities of your business model, customer base, and geographical reach.

As recent regulatory enforcement actions across Singapore have shown, regulators are actively looking for operational effectiveness, not just theoretical policies. Your staff must actually follow the procedures you have laid out.

3. Customer Due Diligence (CDD)

Customer Due Diligence (CDD) is the cornerstone of any Regulated Dealer’s compliance program. You are required to perform CDD when engaging in transactions exceeding S$20,000, or when there is a suspicion of money laundering, regardless of the transaction amount.

4. Mandatory Reporting (CTR and STR)

Regulated Dealers must act as the first line of defense in identifying suspicious financial activity. There are two primary reports you must be prepared to file:

• Cash Transaction Reports (CTR): You must file a CTR within 15 business days if you receive cash exceeding S$20,000 in a single transaction (or multiple linked transactions).
• Suspicious Transaction Reports (STR): If a customer exhibits red flags—such as splitting payments to avoid thresholds, using third-party funds without explanation, or showing unusual nervousness—you are legally obligated to file an STR with the Suspicious Transaction Reporting Office (STRO).

5. Record Keeping and Ongoing Training

If you didn’t document it, it didn’t happen. Regulated Dealers must retain all transaction records, CDD documents, and risk assessments for a minimum of five years. This ensures that a proper audit trail is available if regulatory authorities request an inspection.

Additionally, you must ensure that your employees are adequately trained. A compliance program is only as strong as the staff executing it. Regular training ensures that frontline employees know how to spot red flags, perform KYC checks accurately, and escalate suspicious behavior to the compliance officer.

Conclusion

The regulatory landscape for Precious Stones and Precious Metals Dealers in Singapore is unforgiving to those who cut corners. Treating compliance as an afterthought not only exposes your business to hefty fines but also risks the very license that allows you to operate.

Need assistance bringing your dealership up to standard? Contact Alder today to discuss how we can streamline your AML/CFT compliance operations.

This article is for general information only and does not constitute legal or regulatory advice. Contact Alder for advice specific to your circumstances.