The PSPM Act, Explained: What Registered Dealers Must Actually Do

The PSPM semi-annual return falls due twice a year, on 30 July and on 30 January, and every registered dealer has to file one. MinLaw confirms the exact date to each dealer, so check your own notification. If you deal in gold, bullion, gemstones, or jewellery and watches whose value comes mainly from precious metals or stones, this almost certainly applies to you. Some pawnbrokers are covered too, depending on what else they do.

This guide explains what the PSPM Act asks of you, in plain language, and what the semi-annual return covers. No jargon without an explanation. If you are reading this because you got a letter and searched for what it means, you are in the right place.

What the PSPM Act is

The PSPM Act is the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019. It is administered by the Ministry of Law (MinLaw), not by the Monetary Authority of Singapore. This matters, because the rules, the forms, and the regulator you answer to are all MinLaw’s, and guidance written for banks or payment firms does not apply to you.

The reason the law exists is simple. Precious stones and precious metals are easy to move, hold their value, and can be used to launder money or finance terrorism. So Singapore asks the businesses that deal in them to run basic checks and keep basic records, the same way a bank does, scaled to your size. Since amendments that took effect in 2024, the law also covers proliferation financing, the funding of weapons proliferation, which is now a MinLaw priority.

If you deal in these goods as a business, you are what the Act calls a regulated dealer, and you have to be registered.

PSPM registration: the first obligation

Before you carry on business as a regulated dealer, you must hold a valid PSPM registration.

A quick note on wording, because people search for both. Many dealers look for a “PSPM license.” The correct term under the Act is registration, not a licence, but they mean the same thing in everyday use: the permission you need from MinLaw to operate. PSPM registration is granted by the Registrar of Regulated Dealers.

Registration is not a one-time formality you can forget. It comes with ongoing duties, and the semi-annual return is one of them.

What the PSPM Act actually requires

Once you are a registered dealer, the Act asks you to do a set of things on an ongoing basis. In plain terms:

• Know your customer. For deals where more than S$20,000 is paid in cash, cash equivalents, gold other than jewellery, or digital payment tokens, you must carry out customer due diligence, which means checking who your customer really is before you complete the deal. Two or more sales to the same customer on the same day count together toward that amount. If you are a secondhand dealer buying these goods from a customer who is not themselves a dealer, and you pay out more than that in those same forms of payment, the same checks apply. Bank transfers and card payments do not cross this threshold. Checks are also required whenever something raises your suspicion, whatever the amount, and sanctions screening applies to your customers regardless of how they pay or how much.
• Report large cash transactions. When you receive more than S$20,000 in cash or cash equivalents for a sale, you must file a cash transaction report, Form NP 784, with a Suspicious Transaction Reporting Officer at the Singapore Police Force. You file it no later than 15 business days after the transaction, send a copy to the Registrar of Regulated Dealers when you file, and keep a copy for five years. That copy step is easy to miss, and it is a real obligation. If you take payment in digital payment tokens or gold rather than cash, those trigger the customer checks above, but whether they also require this cash report is not settled from the wording of the rules, so get specific advice on the reporting question.
• Report suspicious transactions. If something about a transaction does not add up, you must file a suspicious transaction report, whatever the amount. These go to the same Suspicious Transaction Reporting Officer through the police’s SONAR online portal, as soon as reasonably practicable once the suspicion forms.
• Keep records. You must keep records of your transactions and your customer checks for at least five years, so you can produce them if MinLaw asks.
• Assess your risk and have policies. You are expected to understand the money-laundering, terrorism-financing, and proliferation-financing risk in your own business and to have written internal policies, procedures, and controls, approved by your senior management, that match it.
• Train your people. Staff who handle transactions should be trained to spot and handle the risks. We deliver AML and CFT training for regulated dealers, built on your own programme.
• Screen against sanctions. You are expected to screen your customers against the United Nations designated-persons lists and Singapore’s terrorist-designation lists, which are lists of names. You also weigh the FATF’s list of higher-risk jurisdictions, which is a list of countries that raises how carefully you treat a customer connected to one.

None of this requires you to be a compliance expert. It requires you to have a system, follow it, and be able to show it.

The semi-annual return, specifically

The semi-annual return is a periodic report every regulated dealer files with MinLaw twice a year. It has been a requirement since 1 January 2021.

There are two reporting periods each year. One runs from 1 January to 30 June. The other runs from 1 July to 31 December. You file within 30 days of a period ending, which is why the deadlines fall on 30 July and 30 January. The July return covers 1 January to 30 June, and the January return covers 1 July to 31 December. MinLaw confirms the date to each dealer directly and has sometimes allowed a day beyond this, so work to the date above and check your own notification. You submit it electronically through myPal, MinLaw’s portal at eservices.mlaw.gov.sg/mypal, using Singpass. There is no separate paper form to track down, and MinLaw does not publish a form number for it. It is simply the semi-annual return.

The return asks about your business activity and your transactions for the half-year, and about your compliance programme. To complete it, you will generally need your records for the half-year to hand: your transactions, the checks you ran, and your current business details.

The practical lesson is that the return is only easy if your records are already in order. Dealers who keep clean records through the half-year complete the return in an afternoon. Dealers who do not spend the last week before the deadline trying to reconstruct six months of transactions from memory and receipts. The return does not create the work. It reveals whether the work was already being done.

Filing the return is part of your obligations as a registered dealer, and MinLaw enforces it. A missed or late return invites regulatory follow-up, counts against you at inspection and at registration renewal, and persistent non-compliance can put the registration itself at risk.

Where dealers commonly come unstuck

Across registered dealers, the same few gaps show up again and again. None of them are exotic. All of them are avoidable.

• Treating registration as the finish line. A dealer registers, files it away, and assumes the obligation is done. The registration is the start of the duties, not the end of them.
• Customer checks that live on paper but not in practice. A policy says the checks happen. In the shop, on a busy day, they do not. The gap only shows up when someone asks for the records.
• Records scattered across notebooks, phones, and memory. When the return comes due, or MinLaw asks, the dealer cannot produce a clean history. What happened is not the problem. Not being able to show it is.
• Assuming small means exempt. A small family business is still a regulated dealer if it deals in these goods above the threshold. Size does not remove the obligation.

What good looks like

A registered dealer who never worries about the PSPM Act is not one with the thickest folder of policies. It is one whose system is alive. That means three things.

It is real. The checks and records actually happen in the course of business, not just on paper.

It is owned. A named person in the business is responsible for it, understands it, and can answer for it. Not a vendor, not a document, a person. This is not just good practice. The Act expects a compliance officer who sits in a management position in the business, which means the accountability is meant to live with someone senior enough to act on it.

It is tested. Someone looks, at least twice a year when the return comes due, and confirms the records are complete and the checks were run. Ideally that someone is not the same person who did the work, because a second set of eyes catches what the first pair stopped seeing months ago.

That is the whole of it. The dealers who stay out of trouble are the ones who built that system once and keep it running, so that a filing deadline is a half-hour of work rather than a week of panic.

If this is more than you can carry alone

Most registered dealers are not compliance specialists, and they should not have to become one to run a jewellery counter or a bullion desk. That is the gap we built Azentiq Nexus Consulting to close. We explain the ongoing-support model in more depth in how a compliance retainer really works in Singapore.

We help you build a framework that meets the PSPM Act, and we bring you and your team up to speed on it, so you understand what you are doing and why. We do the heavy lifting of setting it up and keeping it current. You stay the person who owns it and can answer for it, because that is where the accountability has to sit. The goal is not to make you dependent on us. It is to leave you genuinely capable of running your own obligations, with the work made lighter.

If the next return has you scrambling, or you are not sure your system would hold up if MinLaw asked, we offer a free 15-minute review. No pricing pressure, no obligation. We tell you honestly where you stand and what, if anything, needs fixing.

Book a free 15-minute PSPM review on WhatsApp, or get in touch.

Read the companion guide: Sanctions Screening Starts at Zero. CDD Starts at S$20,000..