The PSPM Act Compliance Guide for a Regulated Dealer in Singapore

Before you read this. This is our own reading of the instruments as they stood on 19 August 2026: the Act, the Regulations and the Guidelines, with the amendments in force on that date. Compliance material dates quickly, and a guideline can be revised without any of the commentary around it changing. Check the current text before acting on anything here. Where our reading and the regulator’s text differ, the regulator’s text governs.

The arrival of a Ministry of Law inspection notice should not set off a scramble. For many regulated dealers, the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019 is experienced mostly as confusing thresholds and a semi-annual return that never feels quite settled. This guide works through the instruments that govern a dealer, the triggers that actually matter, and what a well-run compliance function looks like in practice rather than on paper.

Understanding the PSPM Act 2019 regulatory landscape

The Act exists to keep the precious stones and precious metals trade from being used to move illicit funds, and it applies to any person or business that carries on a business of regulated dealing, or acts as an intermediary for such dealing. A high-street jeweller and a large bullion trader answer to the same obligations. The task for either is to turn broad legal mandates into specific steps their staff actually follow at the counter.

The role of the Ministry of Law

The Ministry of Law is the supervisory authority for this sector. Where financial institutions answer to the Monetary Authority of Singapore, dealers answer to the Anti-Money Laundering and Countering the Financing of Terrorism Division at MinLaw. Registration is the entry requirement for anyone intending to be a regulated dealer, and once registered, the compliance duties are mandatory rather than optional. MinLaw expects every registered dealer to keep its business from being exploited by those seeking to launder money or finance terrorism, and to be able to show the controls that prove it.

The instruments to know, and their order

Effective compliance starts with knowing which rule sits where. The PSPM Act 2019 is the primary legal mandate. The PMLTFPF Regulations 2019 give the procedural detail, including that customer due diligence must be performed for a cash or cash-equivalent payment exceeding S$20,000. Alongside those sits the practical layer: MinLaw’s Guidelines for Regulated Dealers, currently version 5.1 dated 12 May 2026, issued by MinLaw’s AML/CFT Division. It is worth naming these correctly, because they are often mistaken for the Registrar’s work. The Registrar issues notices. These Guidelines come from the AML/CFT Division, and they explain what MinLaw expects a compliance function to look like. The Act and the Regulations use “must” to set a binding duty. The Guidelines describe what MinLaw expects to see, and while they are not themselves the law, a framework that ignores them tends to produce findings.

The compliance obligations and thresholds

Precision matters here, because in this sector a single missed threshold turns into avoidable regulatory friction. Beyond individual transactions, a dealer also has to carry out a risk assessment, which identifies the systemic vulnerabilities in the business model and sits underneath the whole AML and CFT programme.

The S$20,000 designated transaction threshold

Under the PMLTFPF Regulations 2019, customer due diligence is triggered by a designated transaction: one where a payment in cash or a cash equivalent exceeds S$20,000. It is a binary trigger, so a payment of exactly S$20,000 does not yet cross it. This threshold belongs to the Ministry of Law regime for dealers, and importing thresholds from the financial-sector regime is one of the more common ways a dealer’s framework goes wrong. If you are a dealer, this is your rulebook.

When the due diligence has to happen

Timing is its own requirement, and it is one the rules are specific about. Customer due diligence has to be performed before entering into the transaction, not at the point of payment and not after the deal has closed. That applies to every threshold limb, not only to the headline designated payment: it covers a payment in gold other than jewellery exceeding S$20,000 and a payment in digital payment tokens exceeding S$20,000 as well. Reading the duty as something to complete while settling up, rather than before committing, is a common and costly misreading, because by then the transaction is already underway.

Defining cash equivalents, and the case the list does not name

The definition of a designated payment reaches past physical banknotes. Regulation 3(1) of the PMLTFPF Regulations 2019 sets out a closed list of cash equivalents, and it is the list a dealer classifies a payment against:

• a cash cheque or traveller’s cheque
• a payment account containing e-money
• a voucher redeemable for goods or services
• a token, stamp, coupon or other article that entitles the holder to receive any precious stone, precious metal or precious product
• a negotiable instrument in bearer form or transferable by delivery

The list is what you check against, but the Guidelines also give the principle behind it, which is what lets you handle a payment the list does not obviously name. A payment mode is treated as a cash equivalent if it allows anonymity and the identity of the payer cannot be traced. MinLaw’s own examples of that principle include stored value cards, EZ-link cards, cash vouchers and e-money stored in digital wallets, the last of which covers the common wallet apps a customer might pay from. The point the principle makes is a subtle one: the wallet provider may well have identified its own customer, but from the dealer’s side the payer is not traceable, so it falls on the cash-equivalent side.

Applying that principle answers the question a dealer most often actually has. PayNow is not a cash equivalent, because it allows the payer’s identity to be traced. So a payment settled by PayNow does not start the designated-transaction machinery, whereas the same value loaded onto an anonymous stored value card would. Digital payment tokens are a separate matter again: they are not cash equivalents under Regulation 3(1), though the Guidelines still expect a dealer to assess the risk of a token payment.

Sanctions screening duties

A frequent misconception is that screening follows the same S$20,000 threshold as customer due diligence. It does not. Sanctions screening carries no monetary threshold. It is a duty owed before dealing with any customer, whatever the transaction is worth, so a S$100 sale is screened on the same footing as a S$100,000 one. The point is to confirm you are not dealing with a prohibited person or entity, and it has to be settled before the transaction is finalised.

Designing the AML and CFT programme

A programme is more than a list of rules. It has to reflect the actual risks of the business, and it has to be something the staff who use it every day can actually run. The risk assessment is the foundation, and the controls should map to it rather than to a generic template. Training is the other half: it is not enough for a director to understand the rules if the person at the counter cannot recognise the red flags, so training that turns the regulations into practical behaviour is what makes a designated transaction get handled correctly in the moment.

Policy and procedure that survive an inspection

Off-the-shelf manuals are a common failure point, because they do not account for how a particular dealer actually operates and an inspection surfaces that gap quickly. Policies that hold up are bespoke: mapped to the risk assessment, to the real customer base and to the actual product types. A manual that reads well but does not match the desk is precisely what a review is built to catch.

Remediation of regulator findings

A list of findings after an inspection is stressful, but it is also a clear path to a stronger framework. Remediation starts with a gap review, which measures the existing programme against current expectations, and it produces a roadmap that a firm’s own team can work through. Kept as a documented log of what was found and what was fixed, that roadmap also shows a regulator that the firm finds and closes its own weaknesses, which is the difference between continuous improvement and reactive panic.

Regulatory reporting and the semi-annual return

Filing the semi-annual return should be the quiet close to a well-run six months, not a reconstruction under deadline pressure. It is the formal record of a dealer’s compliance with the standards the Act sets. It is also worth keeping separate in your mind from the disclosure of suspicion, which is a different and immediate duty under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act. Treating the periodic return and the suspicious transaction report as one thing is a common error.

What the return covers and when it is due

The return is divided into two reporting periods: 1 January to 30 June, and 1 July to 31 December. Under the PMLTFPF Regulations 2019 you file within 30 days of the period ending, so 30 July and 30 January. In practice MinLaw emails each dealer its own filing date, and that date is usually a day later, 31 July and 31 January, but your own notification governs. The safe habit is to work to the 30th and check the email from MinLaw for your confirmed date.

Filing through the myPal portal

There is no generic MinLaw e-portal for these submissions. They go through the myPal portal at eservices.mlaw.gov.sg/mypal, using your corporate Singpass, and the form is titled the semi-annual return. MinLaw uses these returns to monitor sector trends and individual dealer behaviour, so the accuracy of the data matters, and accuracy depends on capturing transaction records and customer profiles through the year rather than assembling them at the deadline. Those records are kept for five years, and the clock starts on the transaction rather than on the end of the customer relationship, which is the part dealers most often get wrong; the copy of a cash transaction report runs its five years from the date it is submitted.

Strengthening your regulatory foundation

A robust compliance function is a continuous process rather than a one-off. It comes down to aligning daily operations with the specific instruments that govern a dealer, applying the customer due diligence triggers correctly and at the right time, and classifying payments against the cash-equivalent list with the guiding principle to hand for the cases the list does not name. None of it requires a large legal department. It requires a stable, well-organised system that lets an in-house team act with confidence, and a periodic health check against the current text is how a dealer keeps that system honest between inspections.

If you would like a practitioner view of where your framework stands, you can book a scoping call with Azentiq Nexus Consulting to talk it through.

Disclaimer

This article is published by Azentiq Nexus Consulting LLP. It is general information about regulatory obligations. It is not legal advice, and it is not compliance advice for your particular circumstances.

Azentiq Nexus Consulting LLP is a compliance consultancy. We are not a law firm and we do not advise on law. We are not licensed by the Monetary Authority of Singapore and we are not registered with the Ministry of Law. We advise regulated firms; we are not one.

Regulations, thresholds and published guidance change. This article reflects our understanding at the time it was written and may not reflect the current position. Always check the current text published by the relevant regulator, and take advice on your own facts before acting.

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