Recent Updates: Singapore’s Sanctions against Russia

Singapore’s targeted financial measures against Russia remain part of the compliance obligations applicable to financial institutions in Singapore.

The Monetary Authority of Singapore (MAS) re-issued Notice SNR-N01 on Financial Measures in Relation to Russia and Notice SNR-N02 on non-prohibited payments and transactions on 30 June 2025, with the updated notices taking effect on 1 July 2025. SNR-N01 was subsequently amended with effect from 27 February 2026.

These measures apply across Singapore’s financial sector and restrict dealings with designated Russian banks and entities, financing connected with specified controlled goods, certain Russian government fundraising activities and specified activities involving Donetsk and Luhansk.

For financial institutions, compliance therefore requires more than simply screening customer names against sanctions lists. Firms must consider customers, beneficial owners, counterparties, transactions, assets and the underlying purpose of financial services.

What Are Singapore’s Financial Measures Against Russia?

Singapore introduced targeted sanctions and restrictions following Russia’s invasion of Ukraine in February 2022.

The measures were designed to restrict activities that could contribute to Russia’s capacity to conduct war against Ukraine. They include both:

• financial measures applicable to financial institutions; and
• export controls covering specified military and dual-use goods.

MAS administers the financial measures applicable to financial institutions, while Singapore Customs administers Singapore’s strategic goods control framework.

This distinction is important because businesses may have obligations under more than one regulatory regime depending on the transaction.

Which Financial Institutions Are Affected?

The measures apply to financial institutions in Singapore.

This encompasses institutions across the financial sector, including banks, finance companies, insurers, capital markets intermediaries, securities exchanges and payment service providers.

Digital payment token activities are also relevant. Financial institutions must not facilitate digital payment token transactions where they would facilitate prohibited activities or transactions under the applicable measures.

Restrictions on Designated Russian Banks and Entities

MAS Notice SNR-N01 restricts financial institutions from dealing with designated banks and designated entities.

The designated Russian banks include:

• VTB Bank Public Joint Stock Company;
• The Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank;
• Promsvyazbank Public Joint Stock Company; and
• Bank Rossiya.

The definition of a Designated Bank also extends to entities owned or controlled, directly or indirectly, by the identified banks, as well as entities acting on their behalf or under their direction.

Financial institutions must therefore consider ownership and control rather than relying solely on an exact-name sanctions screening result.

Where an institution possesses or controls funds, financial assets or economic resources belonging to a designated party, the applicable asset-freezing requirements under the MAS notice must be followed.

Restrictions Related to Strategic Goods

Singapore also restricts financing connected with specified exports, transhipments and transit of controlled goods to Russia.

Singapore’s strategic goods framework is administered under the Strategic Goods (Control) Act. The current Strategic Goods Control List is contained in the Strategic Goods (Control) Order 2025, which took effect on 1 December 2025.

The framework covers military goods as well as dual-use goods, software and technology that meet the relevant control specifications.

Singapore’s Russia-specific export controls target items that can contribute to military activity or offensive cyber operations.

Financial institutions therefore need to consider the underlying trade transaction when providing financing or other financial services. Screening the names of the parties alone may not identify a transaction involving restricted goods.

Businesses dealing directly with strategic goods should separately assess applicable Singapore Customs permit and export-control requirements.

Restrictions on Russian Government Fundraising

Singapore’s financial measures also restrict certain fundraising activities involving:

• the Russian government;
• the Central Bank of the Russian Federation; and
• entities owned or controlled by them or acting on their behalf or under their direction.

The applicable restrictions cover specified securities and lending transactions within the scope and effective dates established by MAS Notice SNR-N01.

Financial institutions involved in securities, financing or lending activities should therefore assess both the identity of the counterparty and the nature and date of the financial instrument or transaction.

Restrictions Relating to Donetsk and Luhansk

The MAS measures also cover certain transactions and financial services involving specified sectors in Donetsk and Luhansk.

These sectors include:

• transport;
• telecommunications;
• energy; and
• prospecting, exploration and production of oil, gas and mineral resources.

This means geographical exposure and the underlying economic activity can be relevant even where a transaction does not directly involve one of the named Russian banks.

Are All Russia-Related Transactions Prohibited?

No. Singapore’s measures are targeted rather than a blanket prohibition on every Russia-related transaction.

MAS Notice SNR-N02 sets out categories of non-prohibited payments and transactions that are excluded from particular restrictions under SNR-N01, subject to the conditions specified in the notice.

Financial institutions should therefore avoid treating every Russia-linked transaction identically. A transaction should be assessed against the relevant prohibition, any applicable exclusion and the institution’s wider anti-money laundering, sanctions and risk-management controls.

Where an exclusion is relied upon, appropriate records should be maintained to demonstrate the basis on which the transaction was processed.

Practical Compliance Considerations for Financial Institutions

Financial institutions should incorporate Singapore’s Russia-related financial measures into their sanctions and financial crime compliance frameworks.

Customer and Beneficial Owner Screening

Screen customers, beneficial owners and relevant connected parties against applicable designated parties and assess ownership or control relationships.

Transaction Screening

Monitor counterparties, payment information and transaction flows for potential exposure to prohibited parties or activities.

Trade and Purpose Assessment

Where financing or financial services relate to international trade, consider the underlying goods, destination, end-user and transaction purpose.

Digital Payment Token Controls

Ensure digital payment token transactions cannot be used to facilitate or circumvent transactions prohibited under the applicable MAS measures.

Asset-Freezing Procedures

Maintain procedures for identifying and freezing assets where required, including escalation processes for potential matches.

Regulatory Reporting and Escalation

Potential prohibited transactions and assets connected with designated parties should be escalated promptly in accordance with the applicable MAS requirements and the institution’s internal procedures.

Singapore’s Wider Strategic Goods Controls

Financial institutions are not the only businesses affected by Singapore’s restrictions relating to Russia.

Companies involved in exporting, transhipping, transiting, brokering or transferring strategic goods or related technology should assess their obligations under Singapore’s Strategic Goods (Control) Act and current Strategic Goods Control List.

Singapore Customs states that permits or registrations may be required for activities involving strategic goods and related technology. The framework also contains catch-all controls for goods or technology intended, or likely, to be used in connection with weapons of mass destruction.

Businesses should therefore assess both the goods themselves and factors such as the destination, end-user and intended end-use before proceeding with a controlled transaction.

Keeping Russia Sanctions Controls Up to Date

Sanctions and export-control compliance should not be treated as a one-time screening exercise.

Financial institutions should periodically review:

• MAS notices and amendments;
• designated banks and entities;
• customer and beneficial ownership information;
• transaction-screening controls;
• strategic goods classifications;
• Singapore Customs requirements; and
• internal escalation and asset-freezing procedures.

Singapore Customs also notes that Singapore does not generally enforce unilateral sanctions imposed by other countries. However, businesses operating internationally may still be affected by foreign sanctions regimes because of their cross-border operations, counterparties, currencies, banking relationships or other jurisdictional connections.

The applicability of foreign sanctions should therefore be assessed separately from Singapore’s domestic requirements.

How Alder Corporate Services Can Help

Financial institutions and regulated businesses need compliance frameworks that reflect their specific activities, counterparties and regulatory exposure.

Alder Corporate Services can support businesses with reviewing compliance and risk-management frameworks, maintaining regulatory controls and assessing changes to applicable MAS requirements.

Businesses can contact Alder Corporate Services to discuss ongoing regulatory and compliance support.

Frequently Asked Questions

Does Singapore still have sanctions against Russia?

Yes. Singapore’s targeted financial measures against Russia remain in place. MAS re-issued Notices SNR-N01 and SNR-N02 in 2025, and SNR-N01 was subsequently amended with effect from 27 February 2026.

Do Singapore’s Russia sanctions apply to all financial institutions?

MAS’s financial measures apply to financial institutions in Singapore, including institutions such as banks, insurers, capital markets intermediaries and payment service providers.

Are all transactions involving Russia prohibited?

No. Singapore’s measures target specified banks, entities and activities rather than imposing a blanket prohibition on all Russia-related transactions. MAS Notice SNR-N02 also specifies certain non-prohibited payments and transactions.

Do the measures apply to cryptocurrency transactions?

Digital payment token transactions cannot be used to facilitate prohibited transactions or circumvent the applicable financial measures.

Where can businesses check Singapore’s current Russia-related requirements?

Financial institutions should refer to the current MAS notices on financial measures in relation to Russia. Businesses dealing with controlled goods should also review Singapore Customs’ current strategic goods controls and Russia-related export restrictions.