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Singapore unveiled its sanctions against Russia on 5 March 2022. These focus on the control of exports of military and technological goods to Russia and financial measures against Russian banks, entities and activities.

Updated as of 23 March 2022

Singapore Foreign Minister Vivian Balakrishnan addressed Parliament on 28 February 2022 and confirmed in an unprecedented move that Singapore would impose unilateral sanctions on Russia for its invasion of Ukraine. Traditionally, Singapore imposes sanctions on other states based on United Nations resolutions by way of the Monetary Authority of Singapore (MAS). This is the first time since 1978, when Vietnam invaded Cambodia, that Singapore has imposed such sanctions.

In doing so, Singapore has brought itself in line with the ‘first wave’ of sanctions imposed by the UK, U.S. and EU in response to Russia’s aggression.

Singapore has broken away from the ASEAN party line and condemned Russia’s actions. The Foreign Minister espoused the fundamentality of sovereignty, political independence and territorial integrity, principles of particular importance to a small state such as Singapore, whose foreign policy is concerned with the survival of such states within the global arena.

On 5 March 2022, the Singapore Ministry of Foreign Affairs formally released Singapore’s sanctions, which fall into two broad categories:

  1. Export controls on items that may be used as weapons in Ukraine or to contribute to offensive cyber operations.

  2. Financial measures to which all financial institutions in Singapore will be subject that target Russian banks and entities, and fundraising activities benefiting the Russian government.

Export control:

A ban will be implemented on the export, transit and transhipment of all items under the Strategic Goods (Control) Order 2021 which (i) are listed as ‘Military Goods’, and (ii) fall under the ‘Electronics’, ‘Computers’, and ‘Telecoms and Information Security’ categories of the List of Dual-Use Goods, which may have both military and commercial uses.

Financial measures

Financial institutions in Singapore will be prohibited from:

a) Entering into transactions or establishing business relationships with four specified Russian banks: VTB Bank Public Joint Stock Company, The Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank, Promsvyazbank Public Joint Stock Company, and Bank Rossiya. For existing relationships with these banks, all financial institutions must freeze any assets and funds.

b) Providing financing or financial services in relation to the export of goods subject to Singapore’s export controls, from Singapore or any other jurisdiction.

c) Providing financial services to designated Russian non-bank entities involved in the export of controlled goods. For existing relationships with these entities, all financial institutions must freeze any assets and funds. Further details of which entities fall under this category will be provided.

d) Facilitating fundraising activities by the Russian government and central bank, or any entity owned or controlled by them or acting or their behalf. This applies to the sale and purchase of new securities, and prohibits participation in making, or financial services that facilitate new fundraising by, any new loan to these entities.

e) Entering into transactions or providing financial services in the (i) transport, (ii) telecommunications, (iii) energy and (iv) prospecting, exploration and production of oil, gas and mineral resources sectors in Donetsk and Luhansk.

f) Entering into or facilitating any transactions involving cryptocurrencies which circumvent the above prohibitions.

You can read the full sanctions wording on MAS is expected to release further detailed directions to all financial institutions. Given the EU, U.S. and UK have continued to impose increasingly tough measures, particularly on the Russian financial sector, this does beg the question of whether and to what extent Singapore may follow suit.