- 30 days is consistent with the submission periods set by other regulators.If dealers are unable to submit returns on time, the dealers should contact MinLaw.
After I have submitted the semi-annual return, do I still need to file cash transaction reports ("CTRs") via SONAR?
You are required to file all your cash transaction reports ("CTRs") and suspicious transaction reports ("STRs") via SONAR.
Are the “top 5 highest valued transactions” related to sales or purchase? If the highest valued transactions consist of multiple PSPM products in one sales invoice, what should I indicate under “PSPM Product” and transaction value?
The 5 highest valued transactions are related to sales, regardless of your type of customers. It should be based on the invoices/receipts (inclusive of GST) issued to customers.
Where the semi-annual return form only allows you to select one product, please select the product accounting for the highest value amongst the products in that one transaction, if the invoice/receipt consists of multiple PSPM products. For example, if the total sales stated in the invoice is $25,000 which consists of 1 loose diamond ($8,000), 1 loose sapphire ($7,000) and 1 gold bar ($10,000), you can select "Gold Bullion (e.g. pure gold in the form of bars, ingots, or plates)" as the PSPM product and indicate the transaction value as $25,000.
Are there definitions for the products and business activities stated under Section 3: Product Information?
You may wish to hover your mouse cursor over the (i) icon to see the definition of terms, where there are (i) icons. Please note that the mouse-over definitions are for illustrative purposes only and meant for general reference.
Can I provide estimated sales if the sales report is not ready?You are required to submit accurate sales figures.
Could MinLaw only apply the reporting requirement to regulated dealers of higher risk e.g. dealers with cash transactions exceeding SGD 20,000.In order for MinLaw to assess the risk profile of regulated dealers, reliable and consistent information has to be collected from all the regulated dealers.Minlaw will consider introducing different reporting requirements in future, if appropriate.
Could MinLaw send reminders/ notifications prior to the submission deadline for the semi-annual returns?MinLaw will send reminders/ notifications to dealers before the submission deadline.
Dealers had responded to MinLaw’s survey in February 2020. Why is MinLaw requesting for such information again?As the regulated dealers’ business and risk profiles may change over time, MinLaw has to collect information from all the regulated dealers on a regular basis.
Do I need to update my internal policies, procedures and controls ("IPPC") and risk assessment every 6 months?
Regulated dealers are required to ensure that their internal policies, procedures and controls ("IPPC") and risk assessments are up to date by regularly reviewing it, including before launching a new product or a new business practice or before using a new or developing technology for any new or existing product. You may refer to https://acd.mlaw.gov.sg/guidelines/ for more information.
Does designated transaction refer to one transaction above $20,000 at a single point of time?A designated transaction refers to a transaction where payment exceeding $20,000 in value is received in cash or a cash equivalent. Regulated dealers are required to conduct customer due diligence ("CDD") before entering into a designated transaction and file a Cash Transaction Report ("CTR") on that transaction.
There may be a situation where a customer/beneficial owner conducts multiple small cash transactions (less than $20,000 individually) within the same day, but the total value of all the transactions exceeds $20,000. In such a situation, the regulated dealer must perform customer due diligence and file a CTR on all the transactions involving this customer/beneficial owner.
Does the “country/region” of the designated transaction in the semi-annual return form refer to the citizenship of the customer, or the place in which the transaction dealt in?It refers to the country/region of incorporation or citizenship of customer.
Does the business address have to be the ACRA-registered address?
The ACRA-registered address refers to the address that the regulated dealer has registered with ACRA. This address is where all communications and notices to the dealer may be addressed, and the place where the dealer's register and records are kept. It may not be the same as the business address where sales operations or business activities take place.
How will MinLaw ensure that the semi-annual returns/ information submitted for the reporting requirement are kept confidential?All information that regulated dealers provided, including for the reporting requirement/ semi-annual returns will be kept strictly confidential and will not be shared with other dealers.We have strict internal protocols to safeguard the information collected. MinLaw complies with the Government’s requirements on data security and the Official Secrets Act.
I do not keep track of the payment mode for each transaction. How do I indicate the total sales and number of transactions for PSPM products for each payment mode for the 6 months period?
All regulated dealers are required to keep proper records of transactions. You are only required to fill in the total sales and the total number of transactions for the 6 months period, by the payment mode(s) used by your business.
If you do not conduct any transactions using a certain payment mode, you can indicate “0” total sales and “0” total number of transactions for that payment mode.
I had previously received/ I just received my certificate of registration. When do I need to start submitting semi-annual returns?
As a regulated dealer, you will need to submit semi-annual returns twice each year for the following reporting periods:
1 January to 30 June
1 July to 30 July
1 July to 31 December
1 January to 30 January
(of the following year)For example:
If your registration commences on 1 June 2021, you will have to submit your first semi-annual return for the reporting period of 1 January 2021 to 30 June 2021, during the submission period of 1 July 2021 to 30 July 2021.
If your registration commences on 1 July 2021, you will have to submit your first semi-annual return for the reporting period of 1 July 2021 to 31 December 2021, during the submission period of 1 January 2022 to 30 January 2022.