Travellers to declare currency or
bearer negotiable instruments over S$30,000
FrontPage of Article
FREQUENTLY ASKED QUESTIONS
Q1. Why is it necessary to implement the
reporting of cross border movements of CBNI in Singapore?
Criminals, in particular transnational crime
groups, and terrorism financiers around the world have been
known to use cash couriers as a major means of moving physical
funds across borders either to finance their illicit activities
or to launder their ill-gotten gains. As an active and
integrated member of the global economy, Singapore could also be
susceptible to such illegal activities.
Hence, this initiative is part of Singapore’s
overall efforts to combat transnational crime, money laundering
and terrorism financing to require the reporting of cross border
movements of CBNI. This is also in line with international
practices and standards recommended by the Financial Action Task
Force, an inter-governmental body that develops and promotes
policies to combat money laundering and terrorism financing.
Singapore has been a member of FATF since 1991.
Q2. Which countries have implemented the
reporting of cross border movements of CBNI?
The countries include the United States, Spain,
Canada and Australia.
Q3. How does this initiative enhance Singapore’s
The initiative will enable the enforcement
authorities to track suspicious conveyance of CBNI which will
assist them in detecting and identifying instances of money
laundering or terrorism financing.
[For circulation to enforcement agencies only]
Q4. If this initiative is meant to combat
terrorism financing, then why is the threshold so high?
Terrorists do not need significant amount of funds to carry out
acts of terrorism.
Whatever the threshold we adopt, there will be
questions on whether it is too high or too low. There is a need
to strike a balance between detecting cash couriers, which is a
money laundering and terrorism financing vulnerability, and
intruding into the privacy of innocent travellers who are
carrying CBNI for legitimate purposes.
Q5. Why is the threshold currently set at SGD
The threshold of SGD 30,000 (the equivalent of
EUR 15,000) is set in accordance with international standards
recommended by the FATF.
Q6. Is the reporting of cross border movements of
CBNI a form of currency control?
No. There are no restrictions on the type or
amount of CBNI which may be moved into or out of Singapore as
long as a person gives a full and accurate report to the
authorities when the total value of the CBNI exceeds SGD 30,000
or its equivalent in a foreign currency.
Q7. Which government agency is responsible for
enforcing the reporting requirement?
The Commercial Affairs Department of the
Singapore Police Force enforces the reporting requirement in
collaboration with other government agencies like the
Immigration and Checkpoints Authority.
Definition of Terms
Q1. What does it mean to "move into or out of
Under the law, a person moves CBNI out of
Singapore if the person takes or sends the CBNI (whether in a
receptacle or otherwise) out of Singapore while a person moves
CBNI into Singapore if the person brings or sends the CBNI
(whether in a receptacle or otherwise) into Singapore. The word
"send" includes send through the post or by means of another
Q2. What exactly is physical currency?
Under the law, "Physical currency" means the
coin and printed money (whether of Singapore or of a foreign
country) that –
a. is designated as legal tender; and
b. circulates as, and is customarily used
and accepted as, a medium of exchange in the country of
Q3. What is a bearer negotiable instrument?
Under the law, "Bearer negotiable instrument"
a. a traveller’s cheque; or
b. any negotiable instrument that is in
bearer form, indorsed without any restriction, made out to a
fictitious payee or otherwise in such form that title passes
and includes a negotiable instrument that has
been signed but with the payee’s name omitted.
Q4. What is a negotiable instrument?
A negotiable instrument refers to an instrument
(such as a bill of exchange, cheque or promissory note)
representing a sum of money the title to which can be freely
transferred between parties.
Q5. What are some examples of bearer negotiable
A bearer negotiable instrument includes examples
such as bill of exchange, cheque, promissory note, bearer bond,
money order and postal order.
Q6. Are crossed cheques made payable to account
payee only considered bearer negotiable instrument?
Under the definition of BNI, only a negotiable
instrument that is in bearer form, indorsed without any
restriction, made out to a fictitious payee or otherwise in such
form that title passes upon delivery, or which has been signed
but with the payee’s name omitted, qualifies as a BNI.
As such, a crossed cheque is not a bearer
negotiable instrument. On the other hand, a crossed cheque made
payable to account payee without the name of the payee being
stated or if it is payable to bearer as well, then it would be a
bearer negotiable instrument.
Q7. Do electronic transactions e.g. telegraphic
transfers need to be reported?
No. The reporting requirement applies only to
physical movements of CBNI into and out of Singapore.
Q8. Who is an Immigration Officer?
An Immigration Officer is defined to be the
"Controller of Immigration or any immigration officer appointed
under section 3 of the Immigration Act, and includes an officer
of customs". Generally, this would include an officer of the
Immigration and Checkpoints Authority.
Q9. Who is a Suspicious Transaction Reporting
Officer? How is he different from an Authorised Officer?
A Suspicious Transaction Reporting Officer is an
Authorised Officer who has been appointed by the Minister and
gazetted as a Suspicious Transaction Reporting Officer. His role
is to receive, analyse and disseminate suspicious transaction
reports received from the various reporting entities.
Q1. What are the languages used in the CBNI
report form? Are there plans to make the report form available
in more foreign languages?
The CBNI report form is available in 4
languages, namely English, Chinese, Malay and Japanese. This is
consistent with the languages used for Singapore Disembarkation
/ Embarkation Cards. There are no plans at present to make it
available in more languages. However, we are open to introducing
the report forms in more languages, should the number of
visitors from these non-English speaking countries increase.
Q2. What is the rationale/purpose of introducing
the CBNI report form in four languages?
This is part of our efforts to create a
visitor-friendly environment and enhance the convenience of
visitors to Singapore. The CBNI report form in the other three
languages will help visitors who are more conversant in Chinese,
Malay and Japanese.
Q3. Why must the CBNI report be completed in
English and not in the respective languages used?
Filling up the CBNI report in English will help
to facilitate immigration clearance as English is the language
of administration in Singapore.
Q4. What are the basis and/or the determining
factors for selecting the languages used for the CBNI report
The language selection consideration for the
CBNI report form is based on the demand for them. An indication
of such demand will be the number of visitors from these
non-English speaking countries.
Q5. Why are there two different CBNI report
forms for submissions, one for Traveller and the other for
Sender or Recipient of CBNI? What is the difference?
The two types of report forms are designed to
cater for the key modes of movements of CBNI into or out of
Singapore. The CBNI Report (Traveller) is used by travellers
entering or leaving Singapore. The CBNI Report (Sender, Carrier
or Recipient) is used by those sending CBNI out of Singapore or
receiving CBNI in Singapore.
Q6. Will the two types of CBNI report form be in the
English language only?
Each of the two types of CBNI report forms is
available in 4 languages. The languages are English, Chinese,
Malay and Japanese.
Q7. Where can one obtain the CBNI report forms?
The CBNI report forms are available at all
checkpoints, police establishments, Singapore Visitors Centre
and branches of Singapore Post. It will also be available for
download at the websites of the Singapore Police Force and the
Commercial Affairs Department. The report forms can also be
obtained on board flights, ferries and cruise ships.
Q8. What kind of information do I need to provide in
the CBNI report?
The information required includes the
particulars of the person giving the report as well as the type,
amount, movements of the CBNI and the reason for the movement.
If you send or receive CBNI, you should retain the supporting
documents like invoices, acknowledgement receipts, etc, for a
reasonable period in the event the authorities require them to
be produced for investigation.
Q9. Will I receive a copy or acknowledgement
receipt of the CBNI report that I have submitted?
You will not be given a copy of the completed
CBNI report or an acknowledgement receipt.
Q10. Where should I obtain the exchange rate to
translate foreign-denominated CBNI into Singapore dollars?
In determining whether an amount of foreign
currency (including an amount in which a document is
denominated) is equivalent to a Singapore dollar amount, the
amount of foreign currency is to be translated to Singapore
currency at the exchange rate applicable at the relevant time.
As the Singapore dollar is a freely traded currency, there is no
officially prescribed exchange rate. Indications of prevailing
rates may be obtained from major newswires,
banks and websites such as Monetary Authority of Singapore and
Q1. Is it true that only Singapore dollar
denominated CBNI have to be reported?
No. All CBNI, whether in Singapore dollars or in
a foreign currency, must be reported if their total value
exceeds SGD 30,000 or its equivalent in a foreign currency.
Q2. Does the reporting of cross border movements
of CBNI apply to Singaporeans?
Yes. All persons who move CBNI exceeding SGD
30,000 or its equivalent in a foreign currency into or out of
Singapore are required to report.
Q3. If an employee collects CBNI on his
company's behalf and carries it into Singapore and then hands it
over to the company, would both the employee (as a traveller)
and the company (as a recipient) have to report? Since the
employee could be regarded as an agent or a part of the company,
why must the company separately report receipt of the CBNI?
The employee (as a traveller) and the company
(as a recipient) will have to report. In this case, the employee
makes a report in his personal capacity for moving CBNI into
Singapore. The company is a separate legal entity and it is
therefore required to give a report as the recipient of the CBNI.
Q4. If an employee receives CBNI from outside
Singapore on his company's behalf, but neglects to make a give a
report, who will be held liable - the employee or his company?
Either way, would it be fair?
The employee would be held liable for failure to
give a report. The company would be liable if the receipt by the
employee was done within his actual or apparent authority.
Q5. Do I have to give a report if I am moving
CBNI exceeding the prescribed amount into Singapore but I do not
intend to use it in Singapore or give it to a recipient in
Yes. A person needs to give a report as long as
he is physically moving CBNI exceeding the exceeding SGD 30,000
or its equivalent in a foreign currency into or out of
Q6. I am a sender or recipient of CBNI. How do I
submit the CBNI report to a Suspicious Transaction Reporting
You can submit the CBNI report by hand or by
post to the Commercial Affairs Department, Suspicious
Transaction Report Office at 391, New Bridge Road, #06-701,
Police Cantonment Complex, Singapore 088762. You can reach our
office at +65 6557 5480.
Q7. Can I submit the CBNI report by fax?
Yes, the report can be faxed to +65 62236603. If
you are moving CBNI into or out of Singapore, the total value of
which exceeds SGD 30,000 or its equivalent in a foreign
currency, the report should be faxed to the STRO no later than
one business day prior to the moving of the CBNI or if it is not
reasonably practicable to do so, you should fax the report to
the STRO at the first opportunity thereafter but before the CBNI
is moved into or out of Singapore. However, you are still
required to send the original report by hand or by post to the
STRO subsequently as the original report is required for
Persons who receive CBNI from outside Singapore
will be required to submit the report to STRO within five
business days upon receipt. A business day is defined as a day
other than Saturday, Sunday or public holiday.
Q8. Are on-line submissions of CBNI report allowed?
On-line submission of the CBNI report is under
consideration by the Commercial Affairs Department.
Q9. Can I submit CBNI report on a duplicated or
photocopied CBNI report form?
Yes. However, the report will have to be in the
prescribed format and must be duly signed by the person giving
Q10. What happens if I submit the CBNI report
late to the Suspicious Transaction Reporting Officer?
The recipient needs to submit his CBNI report to
a Suspicious Transaction Reporting Officer within 5 business
days, the failure of which is an offence under the law. A
"business day" is defined as a day other than a Saturday, Sunday
or Public Holiday.
Q1. Does a commercial carrier (e.g. airline or
cruise operator) have to give a CBNI report on behalf of their
passengers who are moving CBNI above SGD 30,000 or its
equivalent in a foreign currency?
The commercial carrier is not required to give a
report if the CBNI is in the possession of the carrier’s
Q2. Will a person have to give a CBNI report if
he gets another person to carry part of his cash, say SGD
50,000, such that each person carries less than SGD 30,000?
Both persons may be liable for an offence of
having common intention or abetment by conspiracy to carry more
than SGD 30,000 into or out of Singapore.
Q3. Will a child have to give a CBNI report if
he is carrying CBNI above SGD 30,000 or its equivalent in a
A child 7 years or younger is not required to
make a report. However, in such cases, the parent or guardian
travelling with the child will have to give a report on his
behalf. The failure to do so can constitute an abetment offence.
For all practical purposes, a child would not be carrying SGD
30,000 or more unless this had been given to him by an adult.
The adult would not be able to circumvent the law by requesting
a child to carry his CBNI. As such, the adult would still be
required to give a report if he had given the child the CBNI.
Q4. Can I give a report if I am not sure of the
total amount of CBNI that I am carrying?
Yes. Alternatively, you can approach any
Immigration Officer for clarification or call the Suspicious
Transaction Reporting Office at +65 6557 5480 (available 24/7)
for assistance. You can also visit the Singapore Police Force’s
website for more information.
Q5. What is the punishment if I fail to give a CBNI
A person found guilty of a failure to give a
report shall be liable on conviction to a fine not exceeding SGD
50,000 or to imprisonment for a term not exceeding 3 years or to
Q6. Is it an offence if a person gives a false
CBNI report? Yes. A person found guilty for not giving a full
and accurate report shall be liable on conviction to a fine not
exceeding SGD 50,000 or to imprisonment for a term not exceeding 3
years or to both.
Q7. Where and how do I submit the report? What if
there is no Customs Red Channel at my disembarkation point?
There are Customs Red Channels at most of the checkpoints for
incoming travellers. You should seek help from any Immigration
Officer nearby for the location of the Customs Red Channel at these
checkpoints. You can hand the report to any Immigration Officer at
the Immigration Counter if there is no Customs Red Channel. Outgoing
travellers, on the other hand, have to submit their CBNI reports to
the Immigration Officer at the Immigration Counter before departing
Singapore. Adequate publicity materials will be placed at the
checkpoints to assist you.
Q8. Will there be any assistance for travellers
to fill in the CBNI report forms? A guide on the filling up of
the CBNI report form will be available at the checkpoints. You can
approach any Immigration Officer for clarification or call the
Suspicious Transaction Reporting Office at +65 6557 5480 (available
24/7) for assistance. You can also visit the Singapore Police
Force’s website for more information. [Note: The guide will be
placed at the Singapore Disembarkation / Embarkation Card filling in
counters. The guide will also be available at the SPF website.]
Q9. Do transit travellers need to give a report
if they have CBNI exceeding SGD 30,000 or its equivalent in a
foreign currency? Transit travellers do not need to give a
report as long as they do not enter Singapore with the CBNI through
Q10. I am travelling from another country to
Singapore with CBNI exceeding SGD 30,000. If I had already given a
report on the CBNI at the country which I departed from, must I
still give a report when I arrive in Singapore? Yes. You still
need to give a report under Singapore law. 9
CARGO & POSTAL COURIER
Q1. Does a courier/transport company have to
give a CBNI report on behalf of their customers who are moving
CBNI above SGD 30,000 or its equivalent in a foreign currency?
The courier/transport company is not required to
give a CBNI report if the CBNI is:
a. carried on behalf of another person and
the other person has not disclosed to the courier/transport
company that the goods carried on behalf of the other person
includes CBNI; and
b. that courier/transport company does not
know, and has no reasonable grounds to believe that the
goods carried on behalf of the other person include CBNI.
However, a courier/transport company would have
to give a CBNI report if it is aware that it is carrying CBNI
exceeding SGD 30,000 or its equivalent in a foreign currency,
for its clients.
Q2. Would a Tradenet declaring agent have to
give a CBNI report if he is aware that his customer is moving
CBNI above SGD 30,000 or its equivalent in a foreign currency,
into or out of Singapore?
There is no requirement for the Tradenet
declaring agent to give a report if he is not the one moving or
attempting to move the CBNI into or out of Singapore. It would
be the responsibility of the agent’s customer to ensure that the
report is made to the authorities.
Q3. Does a person have to give a report if he is
importing CBNI above SGD 30,000 or its equivalent in a foreign
Q4. Can a CBNI report be given prior to the
movement of the CBNI into or out of Singapore?
The CBNI report can be pre-filled and handed to
the authorities. If you are moving CBNI into or out of
Singapore, the total value of which exceeds SGD 30,000 or its
equivalent in a foreign currency, you are required by law to
give a report to the STRO no later than one business day (or, if
the report is to be sent by post, no later than two business
days) prior to the moving of the CBNI or if it is not reasonably
practicable to do so, you should give the report to the STRO at
the first opportunity thereafter but before the CBNI is moved
into or out of Singapore.
Q5. What happens if I gave a prior CBNI report
to the authorities but the CBNI was eventually not moved into or
out of Singapore?
You must inform the authorities of the change in
situation as soon as practicable. The failure to do so
could constitute the making of a false report.
Q1. Why does this requirement to report apply only
to the first recipient?
There must be a limit to the extent in which
recipients of CBNI would have to give a report. It would not be
reasonable for everyone who received CBNI to enquire about
whether the CBNI was recently brought into Singapore.
Subsequent movement of the CBNI within Singapore
would not constitute the movement of CBNI into or out of
Singapore. The CBNI is already in Singapore.
Q2. What situations are envisaged regarding
instances where the recipient of CBNI has reasonable grounds to
believe that such CBNI has been moved to him from outside
a. A person who receives CBNI (exceeding the
prescribed threshold of SGD 30,000) from overseas through the
b. A person who causes the CBNI (exceeding the
prescribed threshold of SGD 30,000) to be delivered from
overseas and receives it from a courier that has just entered
c. A person wants to change a large quantity of
foreign currency (exceeding the prescribed threshold of SGD
30,000) into Singapore currency or another currency. The money
changer who records the person's particulars (as required under
the Money Changers and Remittance Businesses Act) notes from his
passport that he has just entered Singapore.
The recipient is only required to report if he
had actual or constructive knowledge that he was in receipt of
CBNI that was moved into Singapore. The recipient is not
required to verify or investigate whether the CBNI was moved
into Singapore. There is also no requirement to report if the
CBNI was obtained from local sources e.g. withdrawal from
another bank, or receipts from local business.
Q3. Would the mere fact that the holder of CBNI
is a foreigner mean that the recipient of CBNI would have to
give a report?
If the recipient did not know that the CBNI had
physically moved into Singapore, and that he is the first
recipient, there would be no need for him to report merely on
the basis that the holder of CBNI is a foreigner. There are many
foreigners who reside and work in Singapore and the CBNI may
have been obtained domestically.
PUNISHMENT AND ENFORCEMENT
Q1. What are the offences under the CBNI reporting
The offences include a failure to give a report,
a failure to provide full and accurate information and a failure
to give the report in the prescribed form.
Q2 What is the Suspicious Transaction Reporting
Office and the powers of a Suspicious Transaction Reporting
The Suspicious Transaction Reporting Office is
the Financial Intelligence Unit of Singapore. Its role in the
CBNI reporting regime is to receive, collate and analyse
information contained in the CBNI report. The Suspicious
Transaction Reporting Officer is an officer of the Suspicious
Transaction Reporting Office and he is authorised under the law
to collect the CBNI report.
Q3. Who will enforce and investigate the CBNI
The Cross Border Cash Enforcement Branch (CEB)
of the Commercial Affairs Department would enforce and
investigate the CBNI reporting offences. CEB operates 24/7.
[For circulation to enforcement agencies only]
Q4. Will there be a leniency or grace period for
"innocent" offenders who may not be familiar with the
No grace period will be given. The public will
be adequately informed of the new CBNI reporting requirement and
of their obligations under the law. There will be reminders
placed strategically at the various checkpoints to remind
travellers of their reporting obligations. A reminder would be
included in the Singapore Disembarkation / Embarkation Card to
remind overseas travellers of their obligations.
Q5. What if a person is unaware of the reporting
requirement, or forgets to report? The punishment of SGD 50,000
fine or up to 3 years imprisonment, or both, seems too harsh.
There will be adequate publicity on the
reporting requirement at all incoming and outgoing checkpoints.
Law enforcement will be circumspect and will take into account
the possibility that a person may not have wilfully failed to
give a report. In such instances, the full force of the law will
not be used against such persons. We will only prosecute in
cases where it is clear that the law was wilfully breached.
Q6. Who can question and / or search the travellers?
Under the law, only an Authorised Officer or an
Immigration Officer have the powers to question and / or search
the travellers. The powers to question the travellers will
include the power to require the traveller to give a report on
the total value of any CBNI that the person has with him. This
can be done using the CBNI Report (Traveller).
[For circulation to enforcement agencies only]
Q7. How will the Commercial Affairs Department
follow-up on foreigners who are suspected to have brought in or
left with CBNI above SGD 30,000 or its equivalent in a foreign
currency but had not submitted a CBNI report and have already
left the country?
Such travellers may be tagged for future
monitoring. Efforts will also be made to ascertain whether the
failure to report is due to genuine oversight or pursuant to a
[For circulation to enforcement agencies only]
Q8. How does Police prevent persons who have
submitted the CBNI report from becoming targets of crime (e.g.
The collection of the CBNI report from
travellers arriving into Singapore will be at the Customs Red
Channel. There are many reasons for which persons present
themselves at the Customs Red Channel and the collection of the
reports would be carried out discreetly. There are also adequate
security measures (e.g. CCTV) at the checkpoints to monitor any
suspicious activities within the checkpoints. Departing
travellers will hand in the CBNI report at the immigration
counters and will be within the safety confine of the transit
areas. Any inspection or verification of CBNI will also be
conducted in a secure and private area and away from curious
[For circulation to enforcement agencies only]
Q9. How will checks be made to verify that the
CBNI report is true? Who will be doing the checks?
Verification of the reported amount will be
carried out by an Immigration Officer in the presence of the
traveller. It shall be conducted in a suitable room where
privacy is assured and witnessed by another officer. Female
suspects will only be searched by female officers.
Q10. What about travellers carrying high value
items like gold, gems and precious metals? Are they not risks of
money laundering or terrorism financing? What action will be
Travellers carrying high value items that are
not CBNI are not required to give a CBNI report. However, if
there are suspicions that such persons are engaging in illicit
activities in Singapore, appropriate action will be taken.
Q1. Some foreign clients bring in CBNI to make
payments to local companies. If the CBNI is a bank draft with
the local company named as the payee, is it subject to the
The bank draft is subject to the reporting
requirement if the bank draft falls under the definition of BNI.
Q2. Some foreign clients may bring into
Singapore CBNI exceeding SGD 30,000 where part of which is for
payment in Singapore and the other part is for payment in other
countries that the foreign clients are going to subsequently. Do
the foreign clients need to report on the part payable in other
Yes. The part payable in other countries needs
to be reported since it has been brought into Singapore.
Q3. Will the reporting of cross border movements
of CBNI affect genuine businesses in Singapore since the foreign
clients sometimes transact in large amounts of cash?
This initiative is not a currency control
measure. There are no restrictions on the type or amount of CBNI
a person can move into or out of Singapore as long as he gives a
full and accurate report to the authorities.
www.spf.gov.sg Media Release 26 Oct