Targeted Financial Sanctions (TFS) — Singapore Regime¶

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Disambiguation note: This file describes Singapore's Targeted Financial Sanctions (TFS) regime, which is distinct from (but parallel to) the AML/CFT regime in MAS Notice 626 (banks), MAS Notice SFA 04-N02 (capital markets intermediaries), MAS Notice 824 (finance companies), and MAS Notice FAA-N06 (financial advisers). An FI must comply with both regimes — TFS is not a subset of AML/CFT. Notice 824, despite legacy KB miscategorisation, is an AML/CFT notice for finance companies, NOT a TFS notice. The actual TFS authority is the FSM Regulations issued under FSM Act section 192, plus the UN Act 2001 and TSOFA — not a single MAS Notice.

This document is a navigation/reference doc, not a full restatement of the regime. The canonical, live source is the MAS landing page at:

https://www.mas.gov.sg/regulation/anti-money-laundering/targeted-financial-sanctions

All substantive obligations below are quoted from or attributed to that page (last updated 21 November 2025 per source). Every paragraph that makes a substantive claim cites the source URL or quotes verbatim from it.

1. What is the TFS regime?¶

Per the MAS landing page: "Targeted financial sanctions under UN Security Council Resolutions (UNSCRs) — Financial institutions (FIs), non-financial institutions and individuals in Singapore required to comply with financial sanction requirements in relation to UN-designated individuals and entities."

In substance, the TFS regime is Singapore's framework for implementing UN Security Council Resolutions (UNSCRs) that impose targeted financial sanctions against specific individuals and entities identified by the UN Security Council (or relevant UN Committees) as contributing to a particular threat to, or breach of, international peace and security. The MAS source notes UNSCRs "issued to address the risks of proliferation of weapons of mass destruction emanating from Iran and the Democratic People's Republic of Korea" as examples.

Source: https://www.mas.gov.sg/regulation/anti-money-laundering/targeted-financial-sanctions

2. Statutory Hierarchy¶

The TFS regime sits across three legal stacks, depending on the regulated population:

2.1 For Financial Institutions (FIs)¶

Per the MAS landing page (verbatim): "MAS gives effect to targeted financial sanctions under the UNSCRs through the Financial Services and Markets Regulations issued pursuant to section 192, read with sections 15(1)(b) and 219(d), of the Financial Services and Markets Act 2022 (FSM Regulations). The FSM Regulations apply to all financial institutions in Singapore."

FSM Act 2022 sec 16 vs sec 192 — the load-bearing distinction. The three AML/CFT notices in this category (Notice 626, SFA 04-N02, Notice 824) plus FAA-N06 are issued under FSM Act 2022 section 16. The TFS regime for FIs is implemented through the FSM Regulations issued under FSM Act 2022 section 192 (read with sections 15(1)(b) and 219(d)). Same statute, different sections, different regimes. Conflating them — e.g. treating Notice 824 as a TFS notice — is a category error.

2.2 For Variable Capital Companies (VCCs)¶

Per the MAS landing page (verbatim): "Variable Capital Companies (VCCs) are required to comply with the Variable Capital Companies (Sanctions and Freezing of Assets of Persons) Regulations 2020 issued pursuant to section 83(1)(b) of the Variable Capital Companies Act 2018."

2.3 For Non-Financial Institutions and Natural Persons¶

Per the MAS landing page: "The UN Act, which was promulgated in 2001, gives the Minister for Law the power to make regulations that are necessary to comply with the sanctions requirements." Non-FIs and natural persons must comply with the UN Regulations made under the United Nations Act 2001.

In addition, "all natural and legal persons also have to comply with other targeted financial sanctions found in the Terrorism (Suppression of Financing) Act" (TSOFA, 2002).

3. Key Obligations for FIs (under FSM Regulations)¶

Per the MAS landing page (verbatim): "Broadly, the FSM Regulations require financial institutions to:

Immediately freeze funds, other financial assets or economic resources of designated individuals and entities;
Not enter into financial transactions or provide financial assistance or services in relation to: (i) designated individuals, entities or items; or (ii) proliferation, nuclear or other sanctioned activities; and
Inform MAS of any fact or information relating to the funds, other financial assets or economic resources owned or controlled, directly or indirectly, by a designated individual or entity."

Additionally (verbatim): "Before engaging in a business relationship or providing a financial service, financial institutions should ensure that they do not deal with designated individuals and entities (as defined in the respective FSM Regulations). Financial institutions are required to screen the names of their customers, including the beneficial owners, against the names (and aliases) of designated individuals and entities."

4. Designated Lists (by reference)¶

Designated lists are maintained by reference to the canonical sources — this document does not enumerate or paraphrase list contents:

UN Consolidated List — published by the UN Security Council
MAS-published list — referenced from "Lists of Designated Individuals and Entities" on the MAS TFS landing page
Terrorist designations under TSOFA — managed by the Ministry of Home Affairs via the Inter-Ministerial Committee — Terrorist Designation (IMC-TD), per the MAS landing page reference

Source: https://www.mas.gov.sg/regulation/anti-money-laundering/targeted-financial-sanctions (section "Lists of Designated Individuals and Entities")

5. Penalties¶

Per the MAS landing page (verbatim):

For FIs (FSM Regulations contravention): "Under the Financial Services and Markets Act 2022, a financial institution that contravenes any FSM Regulations is guilty of an offence and is liable on conviction to a fine not exceeding $1 million."
For natural persons (UN Act contravention): "Under the UN Act, a person who commits an offence against any Regulations made under the UN Act will be liable on conviction, in the case of an individual, to a fine not exceeding $500,000 or to imprisonment for a term not exceeding 10 years or to both; or in any other case, to a fine of up to $1 million."

6. Relationship to AML/CFT (load-bearing disambiguation)¶

TFS and AML/CFT are parallel, distinct regimes. Both apply concurrently to financial institutions in Singapore — an FI is not relieved of its TFS obligations because it has an AML/CFT programme, nor vice versa.

Per the MAS landing page (verbatim): "Financial institutions should also note that aside from the FSM Regulations, there are other targeted financial sanctions (e.g. those found under the Terrorism (Suppression of Financing) Act 2002 ) that they also have to comply with."

The cross-references between the two regimes:

The AML/CFT notices (626 / SFA 04-N02 / 824 / FAA-N06) include CDD and screening requirements that, in practice, generate the customer-data set against which TFS screening is performed
TFS screening is a distinct check performed against UN / MAS / IMC-TD designated lists, not against ML/TF risk indicators
Both regimes feed into the suspicious-transaction reporting workflow but via different statutory triggers (CDSA + TSOFA for the AML/CFT side; the FSM Regulations + UN Act for the TFS side)

Do not infer that any of the four AML/CFT notices (626, SFA 04-N02, 824, FAA-N06) constitute the TFS regime. The TFS regime is sourced from the FSM Regulations (FSM Act sec 192) plus the UN Act and TSOFA.

7. Authoritative Sources¶

MAS TFS landing page (canonical): https://www.mas.gov.sg/regulation/anti-money-laundering/targeted-financial-sanctions
Singapore Statutes Online (UN Act + UN Regulations): referenced from the MAS landing page; full texts available at https://sso.agc.gov.sg/
Ministry of Home Affairs IMC-TD page (referenced in source): for terrorist designations under TSOFA, accessed via the MAS landing page link to "Countering the Financing of Terrorism"
Source MAS PDF resource: "Potential Indicators of Proliferation Financing" (63.1 KB) — https://www.mas.gov.sg/-/media/mas/regulations-and-financial-stability/potential-indicators-of-proliferation-financing.pdf

8. Relevance to Regnify¶

For Regnify's CMS-licensee onboarding population, sanctions screening is a parallel obligation to the AML/CFT measures sourced from MAS Notice SFA 04-N02:

Representative onboarding screening: The Form 3A workflow should include a TFS-screening step performed against the UN / MAS / IMC-TD designated lists in addition to the AML/CFT CDD-aligned background checks. A positive TFS match must trigger immediate freezing obligations (per §3 above) and notification to MAS, separately from any STR filing under the AML/CFT regime.
Fit & Proper integration: TFS-screening results are a relevant data point in the Fit & Proper assessment, but the TFS regime imposes statutory obligations (freeze, no transactions, inform MAS) that are independent of the Fit & Proper outcome.
Record keeping: TFS screening records should be retained alongside the AML/CFT records, aligned with the 5-year retention norm in the AML/CFT notices (the FSM Regulations themselves should be consulted for the precise TFS retention period — this document does not paraphrase regulation text).
No regnify-side determination of designation status: Regnify's role is to facilitate the screening workflow against the canonical lists; designation status itself is determined by the UN, MAS, and IMC-TD per their respective publication processes.