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.

The countries include the United States, Spain, Canada and Australia.

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]

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.

The threshold of SGD 30,000 (the equivalent of EUR 15,000) is set in accordance with international standards recommended by the FATF.

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.

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.

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 person.

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

Under the law, "Bearer negotiable instrument" means –

a. a traveller’s cheque; or

and includes a negotiable instrument that has been signed but with the payee’s name omitted.

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.

A bearer negotiable instrument includes examples such as bill of exchange, cheque, promissory note, bearer bond, money order and postal order.

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.

No. The reporting requirement applies only to physical movements of CBNI into and out of Singapore.

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.

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.

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.

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.

Filling up the CBNI report in English will help to facilitate immigration clearance as English is the language of administration in Singapore.

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.

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.

Each of the two types of CBNI report forms is available in 4 languages. The languages are English, Chinese, Malay and Japanese.

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.

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.

You will not be given a copy of the completed CBNI report or an acknowledgement receipt.

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 exchange

rates may be obtained from major newswires, banks and websites such as Monetary Authority of Singapore and Singapore Customs.

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.

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.

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.

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.

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 Singapore.

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.

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 evidential purposes.

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.

On-line submission of the CBNI report is under consideration by the Commercial Affairs Department.

Yes. However, the report will have to be in the prescribed format and must be duly signed by the person giving the report.

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.

The commercial carrier is not required to give a report if the CBNI is in the possession of the carrier’s passenger.

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.

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.

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.

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 both.

The courier/transport company is not required to give a CBNI report if the CBNI is:

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.

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.

Yes.

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.

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.

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.

a. A person who receives CBNI (exceeding the prescribed threshold of SGD 30,000) from overseas through the postal service.

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 Singapore.

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.

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.

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.

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.

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]

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.

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.

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]

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 criminal intent.

[For circulation to enforcement agencies only]

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 bystanders.

[For circulation to enforcement agencies only]

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.

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.

The bank draft is subject to the reporting requirement if the bank draft falls under the definition of BNI.

Yes. The part payable in other countries needs to be reported since it has been brought into Singapore.

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.