MAS Notices on Financial Measures Relating to Russia Sanctions: Impact on Financial Institutions in Singapore

On 14 March 2022, the Monetary Authority of Singapore ("MAS") issued two Notices to all financial institutions ("FIs") in Singapore detailing the financial measures imposed by the Singapore Government against designated Russian banks, entities and activities in Russia and fund-raising activities benefiting the Russian government and related parties.

These Notices took effect on 14 March 2022 and apply to all FIs, including all banks, finance companies, insurers, capital markets intermediaries, securities exchanges and payment service providers (including digital payment token ("DPT") service providers). Failure to comply with the requirements in the MAS Notices is an offence.

MAS Notice SNR-N01 Financial Measures in Relation to Russia ("MAS Notice SNR-N01") sets out the activities and transactions that FIs are prohibited from engaging in (unless relevant exemption(s) apply). Such prohibited activities and transactions include, among other things:

1. Dealing with designated Russian Banks and Designated Entities in the manners set out in Paragraph 3 of MAS Notice SNR-N01 (including establishing business relations with or undertaking any financial transaction for, or providing any financial assistance or service to, or transfering any financial assets or resources to, the designated Russian Banks and Designated Entities).

The designated Russian Banks are:


• VTB Bank Public Joint Stock Company;
• The Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank;
• Promsvyazbank Public Joint Stock Company;
• Bank Rossiya;

and all entities owned or controlled by, directly or indirectly, or acting on behalf of or under the direction of, these Russian banks.

A "Designated Entity" refers to an entity involved in activities relating to the export from, transhipment in or transit through, Singapore or any other jurisdiction to Russia of strategic military and high technology goods that are prescribed in the Strategic Goods (Control) Order 2021, and all entities owned or controlled, directly or indirectly, or acting on behalf of or under the direction of the Designated Entity.


2. Entering into financial transactions or arrangements, or providing financial services, that facilitate fund raising by the Russian government and the Central Bank of the Russian Federation, as well as any entity owned or controlled by them or acting on their direction or behalf.


3. Entering into or facilitating any DPT transaction where the proceeds or benefits from such transaction may be used to facilitate any of the transactions or activities that is stated to be prohibited in Paragraphs 3 to 6 of MAS Notice SNR-N01.

For the full list and details of the activities and transactions that FIs are prohibited from engaging in, please refer to MAS Notice SNR-N01. 

MAS Notice SNR-N02 Financial Measures in Relation to Russia – Non-prohibited Payments and Transactions ("MAS Notice SNR-N02") sets out payments and transactions that are excluded from the scope of the financial measures in MAS Notice SNR-N01. For instance, among other things, in respect of Paragraph 3 of MAS Notice SNR-N01, an FI may process or facilitate payments for basic expenses and reasonable fees for the designated Russian Banks and Designated Entities in respect of certain services specified in Paragraph 3 of MAS Notice SNR-N02. The FI must keep accurate, complete and readable records of these permitted transactions.  

For more information, click here to read our Legal Update.