AML Supervision of Precious Stones and Metals Dealers by the Ministry of Law
In a Nutshell
The Ministry of Law regulates registered dealers under the PSPM Act 2019 for AML, CFT and CPF purposes. The Registrar of Regulated Dealers administers the regulatory regime.
The Registrar of Regulated Dealers, appointed under the PSPM PMLTFPF Act 2019, administers the regulatory regime for registered dealers, including registration, regulatory reporting, inspections and regulatory action.
Cash is the trigger. Designated transactions trigger customer due diligence and cash transaction reporting. Certain prescribed transactions involving payment in gold or digital payment tokens exceeding S$20,000 trigger the applicable customer due diligence requirements. CDD is also required in other circumstances prescribed under the PSPM Act and Regulations.
This is a higher risk sector. High value goods that store and move value attract laundering and, more recently, scam related money laundering, which is why the Division supervises it closely and issued a dedicated code of practice in 2026.
AML Supervision of Precious Stones and Metals Dealers
Precious stones, precious metals, and precious products can present money laundering, terrorism financing, and proliferation financing risks because of their value, portability, and other characteristics. In Singapore, registered dealers are regulated by the Ministry of Law through the Registrar of Regulated Dealers for AML, CFT and CPF purposes under the PSPM Act and Regulations. This guide explains the regulatory framework, registration requirements, reporting obligations, supervisory approach and enforcement framework applicable to regulated dealers.
For the full set of supervisors, see the guide to AML supervisory authorities. For the underlying statutes, see the AML laws and regulations in Singapore pillar. Dealers who want the detailed compliance mechanics should read our AML/CFT regulatory framework for PSMDs. This page is about the Ministry of Law as a supervisor.
Legal Basis and Who Is a Regulated Dealer
The regime rests on the Precious Stones and Precious Metals Prevention of Money Laundering, Terrorism Financing and Proliferation Financing Act 2019 and the Regulations made under it. The Act provides for the appointment of the Registrar of Regulated Dealers. It regulates persons carrying on a business of regulated dealing or acting as intermediaries for regulated dealing, subject to the statutory requirements, exclusions and exemptions.
The S$20,000 threshold applies to designated transactions involving cash or cash equivalents and to certain prescribed circumstances involving payment in gold, other than jewellery, or digital payment tokens. The prescribed gold and digital payment token transactions trigger the applicable CDD requirements and are not, by themselves, designated transactions for CTR purposes.
The Regulations also prescribe certain transactions involving payment in gold, other than jewellery, or digital payment tokens exceeding S$20,000. Multiple transactions within a single day may be aggregated in the circumstances specified by the Act and Regulations. CDD is also required where the dealer has reason to suspect ML, TF or PF, where there is reason to doubt the veracity or adequacy of earlier CDD information, and in other prescribed circumstances.
The definition of precious product covers specified jewellery, watches, apparel, accessories, ornaments and other finished products made up of, containing or having attached to them precious stones or precious metals, where the statutory conditions are met. The Regulations prescribe a net price of S$20,000 for the relevant limb of the definition. The PSPM Act also contains provisions relating to asset backed tokens, subject to its statutory scope and exclusions.
Why this Sector is Watched
Singapore’s 2024 Money Laundering National Risk Assessment identifies precious stones and precious metals dealers as a medium high ML risk sector. It notes that precious stones and precious metals have high intrinsic value in a relatively compact form and may be used to store or move illicit value. Singapore’s 2024 Proliferation Financing National Risk Assessment also identifies precious stones and precious metals dealers as a sector exposed to higher PF risks.
The Current Guidance Stack
The Ministry of Law publishes Guidelines for Regulated Dealers to help dealers understand the regulatory requirements under the PSPM Act and Regulations. The current Guidelines are version 5.1, published on 12 May 2026. They cover areas including risk assessment, CDD, ECDD, beneficial ownership, ongoing monitoring, targeted financial sanctions and reporting. The Ministry of Law also provides sample forms, checklists and a Compliance Toolkit. On 2 April 2026, the Registrar issued a Code of Practice providing PSMDs with guidance on AML measures to combat scam related money laundering cases.
We help regulated dealers register, build the CDD and cash transaction report workflow, and file accurate semi annual returns on time.
How the Ministry of Law Supervises
The Ministry of Law applies a risk based and data informed approach to the supervision of regulated dealers. The supervisory framework considers the ML, TF and PF risks associated with the sector and the individual dealer, supported by regulatory data, inspections, compliance reviews and industry engagement.
It starts with registration and regulatory requirements at the gate. Once registered, dealers submit semi annual returns and are subject to inspections, supervisory guidance and regulatory action. The Registrar may take action where the PSPM Act or Regulations are contravened or where it is contrary to the public interest for the dealer to continue regulated dealing or business as an intermediary. Regulatory action may include suspension or cancellation of registration.
The Registrar may take regulatory action where the PSPM Act or Regulations are contravened, or where it is contrary to the public interest for the dealer to continue carrying on regulated dealing or business as an intermediary. Such action may include suspension or cancellation of registration.
Regulated dealers are required to maintain appropriate internal policies, procedures and controls commensurate with their ML, TF and PF risks. The Guidelines set out expectations concerning risk assessment, CDD, reporting, training and the oversight responsibilities of directors and senior management. The Ministry of Law has also issued guidance and conducted supervisory and industry engagement activities to strengthen AML, CFT and CPF controls in the sector.
The Semi Annual Return Calendar
The semi annual return is a mandatory reporting requirement for regulated dealers. There are two reporting periods each year, from 1 January to 30 June and from 1 July to 31 December. The return must be submitted to the Ministry of Law within 30 days after the end of each reporting period through the prescribed electronic submission channel.
Reporting period | Covers | Return due |
First half | 1 January to 30 June | Within 30 days after 30 June, normally 1 to 30 July |
Second half | 1 July to 31 December | Within 30 days after 31 December, normally 1 to 30 January |
The Ministry of Law requires regulated dealers to submit semi annual returns containing information about their business and transactions. Filing the returns accurately and within the prescribed period is a regulatory requirement. Our guide to submitting the semi annual return walks through the mechanics, and dealers that find the process burdensome can get help rather than file late.
CDD, Cash Reports and Suspicious Reports as Supervisory Evidence
What the Registrar inspects is the evidence a dealer produces around cash. When a regulated dealing involves cash or cash equivalents above S$20,000, the dealer must identify and verify the customer, screen them, and, where the risk is higher, or the customer is a politically exposed person, apply enhanced due diligence. It must also file a cash transaction report, on the prescribed form, to the Registrar. Simplified due diligence is available only in limited, lower risk circumstances and, in defined cases, with the Registrar’s prior written approval, so it is the exception rather than the norm.
Where a regulated dealer has suspicions of ML, TF or PF activities, it must submit an suspicious transaction report to STRO as soon as reasonably practicable after suspicion is established. The current Guidelines state that this should be no later than five business days. STRs for higher risk cases such as targeted financial sanctions or sanctions cases are to be filed within one business day, if not immediately. A copy of the STR must also be submitted to the Registrar. The Registrar’s inspection will test whether the reports were made and whether the underlying designated transactions were properly assessed.
Two further points round out what the Registrar inspects. First, beneficial ownership: where the customer is an entity or legal arrangement, the dealer must identify and verify the beneficial owner in accordance with the applicable requirements and exemptions. Second, records: the dealer must keep the required records for the prescribed period, including after the business ceases to be registered where applicable. For higher risk customers and transactions, the Guidelines provide for appropriate enhanced measures concerning the customer’s source of wealth and source of funds.
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The Ministry of Law and the National Strategy
Singapore’s 2024 Money Laundering national risk assessments assesses the precious stones and precious metals dealers sector as presenting medium high ML risk. Singapore’s 2024 Proliferation Financing National Risk Assessment identifies precious stones and precious metals dealers as a sector to watch for PF risks. The 2024 Terrorism Financing National Risk Assessment assesses the sector as medium low TF risk. In April 2026, the Registrar issued a Code of Practice addressing scam related money laundering involving precious metals, jewellery and luxury watches.
Enforcement and the FATF Assessment
The Registrar may take regulatory action against registered dealers under the PSPM Act. The PSPM Act and Regulations also provide for statutory offences and penalties for specified breaches.
Route | Consequence |
Warning and remediation | Directions to fix control gaps, with follow up |
Composition | Composition of specified offences for a sum, in lieu of prosecution |
Registration action | Suspension or cancellation of registration, stopping the dealer from operating |
Criminal offences | Fines and other sanctions under the PSPM Act, for example dealing without registration or reporting failures |
The Ministry of Law reported in May 2026 that FATF had published Singapore’s 2026 Mutual Evaluation Report, following the assessment of Singapore’s AML, CFT and CPF framework. The Ministry stated that the report affirmed Singapore’s robust and effective framework for combating money laundering, terrorism financing and proliferation financing.
Putting Supervision into Practice
What the Registrar of Regulated Dealers Looks At
Cash threshold discipline: whether the dealer performs CDD for designated transactions, including relevant transactions involving cash or cash equivalents exceeding S$20,000 and specified transactions involving gold or digital payment tokens exceeding S$20,000.
Cash transaction reports: whether these are filed accurately and on time.
Semi annual returns: whether the returns are complete and submitted within 30 days of each period.
Screening and anti scam controls: whether screening runs and the anti scam expectations are met.
Worked example (illustrative)
A dealer sells gold bars for S$25,000 in cash to a walk in customer and records only the customer’s name. The transaction is a designated transaction because the dealer received cash exceeding S$20,000. The dealer must therefore perform the applicable CDD measures and submit a CTR to STRO within 15 business days. A copy of the CTR must also be submitted to the Registrar. Recording only a name would not satisfy the applicable CDD requirements.
Your reporting line: STRO
Whoever supervises you, you report suspicion to the same place. File a STR with the STRO as soon as reasonably practicable after suspicion is established, in accordance with the applicable reporting requirements. The current Guidelines state that an STR should generally be filed no later than five business days after suspicion is established, with a one business day timeline for higher risk cases and targeted financial sanctions cases, if not immediately.
Conclusion
The Ministry of Law regulates registered dealers for AML, CFT and CPF purposes through a framework that includes registration, customer due diligence, reporting, record keeping, ongoing monitoring and targeted financial sanctions requirements.
The S$20,000 threshold applies to designated transactions involving cash or cash equivalents and features in certain prescribed circumstances involving payment in gold or digital payment tokens, with the applicable obligations depending on the transaction and circumstances.
Report suspicions to the AML Suspicious Transaction Reporting Office, and if you need the programme, forms or returns handled properly, our AML health check is built for this sector.
Frequently Asked Questions
The Ministry of Law, through its Anti Money Laundering and Countering the Financing of Terrorism Division and the Registrar of Regulated Dealers, regulates registered dealers under the Precious Stones and Precious Metals Prevention of Money Laundering, Terrorism Financing and Proliferation Financing Act 2019 for AML, CFT and CPF purposes.
The Anti Money Laundering and Countering the Financing of Terrorism Division supports the Ministry of Law’s regulation and supervision of registered dealers for AML, CFT and CPF purposes. The Registrar administers the regulatory regime, including registration and regulatory action.
The Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019 and the Regulations made under that Act form the principal statutory framework for regulated dealers.
There are two reporting periods, 1 January to 30 June and 1 July to 31 December, and a return is due within 30 days of the end of each, normally in July and January respectively. Confirm the exact window against the current instruction guide.
When it carries out a designated transaction or a transaction in prescribed circumstances, a regulated dealer must perform the applicable CDD measures. Designated transactions include specified transactions involving cash or cash equivalents exceeding S$20,000. Prescribed circumstances also include specified transactions involving payment in gold, other than jewellery, or digital payment tokens exceeding S$20,000. CDD is also required where the dealer has reason to suspect ML or TF or has reason to doubt the veracity or adequacy of earlier CDD information, as well as in other prescribed circumstances.
A Code of Practice issued by the Registrar of Regulated Dealers on 2 April 2026 under section 35(1) of the PSPM Act to provide AML measures for PSMDs to combat scam related money laundering. It covers scam typologies involving precious metals, jewellery and luxury watches, as well as relevant red flags and response measures.
Yes. The Registrar may take regulatory action where the PSPM Act or its regulations are contravened, or where it is contrary to the public interest for the dealer to continue carrying on regulated dealing or business as an intermediary. The Registrar may suspend or cancel registration in the circumstances provided by the Act.
About the Author
Pathik Shah
FCA, CAMS, CISA, CS, DISA (ICAI), FAFP (ICAI)
Pathik is a Chartered Accountant with more than 26 years of experience in governance, risk, and compliance. He helps companies with end-to-end AML compliance services, from conducting Enterprise- Wide Risk Assessments to implementing the robust AML Compliance framework. He has played a pivotal role as a functional expert in developing and implementing RegTech solutions for streamlined compliance.
