Transaction-Based Requirements (ACD web page)

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3. Transaction-Based Requirements # Transaction-Based Requirements Learn about transaction-based requirements, including Customer Due Diligence, Enhanced Customer Due Diligence, and filing of Cash Transaction Reports and Suspicious Transaction Reports. Last updated 23 May 2026 On this page - [Customer Due Diligence](#6d2e0ecd824e7a1b90887a043d0e530b) - [Enhanced Customer Due Diligence](#391c83a06bd9485f51b85b12c5c84d66) - [Cash Transaction Report](#9aa2f7f08bc409e331c067441ec37926) - [Suspicious Transaction Report](#9b1096e32879f33b80b2ed9e74b7c740) The transaction-based requirements that apply to regulated dealers include, but are not limited to, the following: - Perform Customer Due Diligence ("**CDD**") or Enhanced Customer Due Diligence ("**ECDD**") measures under circumstances that are prescribed by the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019 ("**PSPM Act**"). - File Cash Transaction Report ("**CTR**") with the [Suspicious Transaction Reporting Office ("STRO") ↗ (opens in new tab)](https://www.police.gov.sg/Advisories/Commercial-Crimes/Suspicious-Transaction-Reporting-Office) for cash and cash equivalent transactions exceeding S$20,000. Apply for a [STRO Online Notices and Reporting platform ("SONAR") account ↗ (opens in new tab)](https://www.police.gov.sg/sonar) to e-file your CTR. By e-filing via SONAR, a copy of the CTR would be extended to ACD. - File Suspicious Transaction Report ("**STR**") with [STRO ↗ (opens in new tab)](https://www.police.gov.sg/Advisories/Commercial-Crimes/Suspicious-Transaction-Reporting-Office) where there is suspicion of money laundering/terrorism financing/proliferation financing ("**ML/TF/PF**"). Apply for a [SONAR account ↗ (opens in new tab)](https://www.police.gov.sg/sonar) to e-file your STR. By e-filing via SONAR, a copy of the STR would be extended to ACD. - Subscribe to the [Monetary Authority of Singapore ("MAS") ↗ (opens in new tab)](https://www.mas.gov.sg/subscription-services) and [Ministry of Home Affairs ("MHA") ↗ (opens in new tab)](https://www.mha.gov.sg/what-we-do/managing-security-threats/countering-the-financing-of-terrorism/) websites for the lists of designated individuals and entities and terrorist designation. You will be alerted via email whenever there is an update to the lists. **Transaction-Based Requirements for Precious Stones and Precious Metals Dealers (“PSMD”):** Watch the videos to find out more about the transaction-based requirements.  - [English ↗ (opens in new tab)](https://youtu.be/g6HGL8SHrQY) - [Mandarin ↗ (opens in new tab)](https://youtu.be/CpUUhEWT59Q) - [Malay ↗ (opens in new tab)](https://youtu.be/7ESKY_2SfXU) - [Tamil ↗ (opens in new tab)](https://youtu.be/oUAsmTT7Odw) [Transaction-Based Requirements for PSMD Sector ↗ (opens in new tab)](https://isomer-user-content.by.gov.sg/473/7ae938ca-8081-47b0-94ab-b484b013eed9/TransactionBasedRequirementsPoster.pdf)  ## Customer Due Diligence CDD is the process of obtaining your customers' identifying information, recording the information and verifying who they are before transacting with them. The objective is to help you determine the money laundering/terrorism financing/proliferation financing ("**ML/TF/PF**") risks and take appropriate mitigating measures to address them. In the event where you are unable to perform or complete the required CDD, you must not proceed with the transaction. You should terminate any transaction entered into with the customer and consider whether to file a STR. If you suspect that the customer is in the listings for terrorist designation and designated individuals and entities, you must stop the transaction and report to the police. Please refer to the [Guidelines ↗ (opens in new tab)](https://isomer-user-content.by.gov.sg/473/2651485f-2f73-49ef-8c38-8fdd785ddc80/guidelines_for_regulated_dealers_120526_v5_1.pdf) (Published Date: 12 May 2026) for more information. ## Enhanced Customer Due Diligence Where the ML/TF/PF risks are identified to be higher, regulated dealers are expected to take ECDD measures to mitigate and manage those risks. Please refer to the [Guidelines ↗ (opens in new tab)](https://isomer-user-content.by.gov.sg/473/5e939bc5-e0ec-46ee-85de-3fd92dbe2949/guidelines_for_regulated_dealers_120526_v5_1.pdf)(Published Date: 12 May 2026) for more information. ## Cash Transaction Report Regulated dealers who enter into any designated transaction¹ must submit a CTR electronically to the STRO within 15 business days via [SONAR ↗ (opens in new tab)](https://www.police.gov.sg/sonar). As part of record keeping, you are required to keep a copy of the filed CTR for 5 years after the date of submission. Definition of Designated Transaction <table> <colgroup> <col style="width: 100%" /> </colgroup> <thead> <tr class="header"> <th><p>“Designated transaction” means any of the following transactions conducted wholly or partly in Singapore:</p> <p>(a) a sale of any precious stone, precious metal, precious product or asset‑backed token by a regulated dealer to a customer, for which cash or a cash equivalent exceeding the threshold amount is received as payment;</p> <p>(b) 2 or more sales of any precious stone, precious metal, precious product or asset‑backed token in a single day by a regulated dealer to the same customer, or to customers whom the regulated dealer knows act on behalf of the same person, for which cash or a cash equivalent in total exceeding the threshold amount is received as payment;</p> <p>(c) a purchase of any precious stone, precious metal or precious product from a customer (who is not a regulated dealer) by a regulated dealer (who is a secondhand goods dealer), for which cash or a cash equivalent exceeding the threshold amount is received as payment;</p> <p>(d) a redemption of an asset‑backed token from a customer (who is not a regulated dealer) by a regulated dealer, for cash or a cash equivalent exceeding the threshold amount;</p> <p>(e) 2 or more purchases of any precious stone, precious metal or precious product in a single day by a regulated dealer (who is a secondhand goods dealer), from the same customer, or customers whom the regulated dealer knows act on behalf of the same person (none of whom are regulated dealers), for which cash or a cash equivalent in total exceeding the threshold amount is received as payment;</p> <p>(f) 2 or more redemptions of any asset‑backed token in a single day by a regulated dealer from the same customer, or customers whom the regulated dealer knows act on behalf of the same person (none of whom are regulated dealers), for cash or a cash equivalent exceeding the threshold amount;</p> <p>“threshold amount” means S$20,000 or its equivalent in value, or an amount prescribed in substitution.<br /> </p></th> </tr> </thead> <tbody> </tbody> </table> ## Suspicious Transaction Report Regulated dealers are required to file a STR when there are suspicions on ML/TF/PF activities in the business transaction. This should be filed electronically via [SONAR ↗ (opens in new tab)](https://www.police.gov.sg/sonar). Regulated dealers are reminded that it is an offence under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act ("**CDSA**") to tip off another person on a STR filed with STRO. Please refer to the [STRO website ↗ (opens in new tab)](https://www.police.gov.sg/Advisories/Commercial-Crimes/Suspicious-Transaction-Reporting-Office) on how to file a STR. Back to [Compliance](/compliance/) ## Other pages in Compliance - [Entity-Based Requirements](/compliance/entity-based-requirements/) - [Other Regulatory Requirements](/compliance/other-regulatory-requirements/) - [Red Flag Indicators](/compliance/red-flag-indicators/) - [AML/CFT/CPF Supervisory Expectations](/compliance/aml-cft-cpf-supervisory-expectations/) - [Offences/Breaches under the PSPM Act and PMLTF Regulations](/compliance/offences-breaches-under-the-pspm-act-and-pmltf-regulations/) - [Compliance Review Programme](/compliance/compliance-review-programme/) - [AML/CFT/CPF Resources](/compliance/aml-cft-cpf-resources/) [See all pages](/compliance/) Back to top ## Anti-Money Laundering / Countering the Financing of Terrorism Division [Regulation](/regulation/)[Regulated Dealers](/regulated-dealers/)[Compliance](/compliance/entity-based-requirements/)[Customers](/customers/)[News](/news/) About MinLaw (opens in new tab)Our Vision, Mission and Core Values (opens in new tab)Our Management (opens in new tab)Organisation Structure (opens in new tab)What We Do (opens in new tab)FAQ (opens in new tab) ### Reach us Contact (opens in new tab) © 2026 Government of Singapore, last updated 24 September 2026 Report Vulnerability (opens in new tab)[Privacy Statement](/privacy/)[Terms of Use](/terms-of-use/)REACH (opens in new tab) [](https://www.isomer.gov.sg) Made with Isomer (opens in new tab)[](https://www.open.gov.sg) Built by Open Government Products (opens in new tab) ## Anti-Money Laundering / Countering the Financing of Terrorism Division [Regulation](/regulation/)[Regulated Dealers](/regulated-dealers/)[Compliance](/compliance/entity-based-requirements/)[Customers](/customers/)[News](/news/) About MinLaw (opens in new tab)Our Vision, Mission and Core Values (opens in new tab)Our Management (opens in new tab)Organisation Structure (opens in new tab)What We Do (opens in new tab)FAQ (opens in new tab) ### Reach us Contact (opens in new tab) © 2026 Government of Singapore, last updated 24 September 2026 Report Vulnerability (opens in new tab)[Privacy Statement](/privacy/)[Terms of Use](/terms-of-use/)REACH (opens in new tab) [](https://www.isomer.gov.sg) Made with Isomer (opens in new tab)[](https://www.open.gov.sg) Built by Open Government Products (opens in new tab)