Sanctions Screening Starts at Zero. CDD Starts at S$20,000.

Picture a dealer who settles every sale by bank transfer. No cash, ever. That dealer has worked out something correct: with no cash and no cash-equivalent payments, they have no designated transactions, so the S$20,000 threshold that triggers customer due diligence never fires for them.

Then they draw a second conclusion that feels like it follows: if the threshold never fires, they have no screening duty either.

The first conclusion is right. The second does not follow. Sanctions screening does not care how anyone pays, or how much. If you have been looking for the sanctions screening threshold, that is the answer: there is not one. It is the duty dealers most often tie to a number that was never attached to it.

What the S$20,000 is actually attached to

The S$20,000 is real. It sits in the PSPM Act at section 15. But read what it attaches to. It attaches to a “designated transaction,” and a designated transaction means a sale or purchase against payment in cash or a cash equivalent exceeding that amount.

“Cash equivalent” is not a loose idea. It is a closed list in Regulation 3: cash cheques and traveller’s cheques, payment accounts holding e-money, vouchers redeemable for goods or services, tokens, stamps or coupons redeemable for precious stones or metals, and negotiable instruments in bearer form.

A bank transfer is not on that list. Neither is a card payment. Our earlier guide on the PSPM Act made the same point: those payment methods do not cross the threshold.

So the designated transaction trigger is tied to the method of payment. A dealer who never takes cash or a cash equivalent never has a designated transaction.

That is not the same as having no customer due diligence duty, and this is where the reasoning most often goes wrong. Two other payment methods carry their own S$20,000 trigger under Regulation 4A: payment taken in gold, other than in the form of jewellery, and payment taken in digital payment tokens. Either of those above the threshold requires customer due diligence, even though neither creates a designated transaction. Same-day sales to the same customer aggregate for both.

For a bullion dealer, the one to watch is a customer who pays with gold. If someone settles a S$30,000 purchase by handing over gold bars, that is payment taken in gold and it requires customer due diligence, even though no cash changed hands. The test is simple: is the gold the price, or is the gold the goods? A customer paying with gold is caught. A customer selling you gold is not, at least not by this limb.

Two things worth adding for the dealers who do take cash. First, the amount aggregates. Four cash sales of S$6,000 to the same customer in one day cross the threshold together, and so do same-day sales to different people the dealer knows are acting for the same person. Dealers tend to think in single transactions; the rule does not. Second, the designated transaction is only one of the circumstances that trigger customer due diligence. Section 16 also attaches it to suspicion, at any amount, and to doubts about the veracity or adequacy of identification information you already obtained. Both of those are threshold-free too.

What the screening duty is attached to

Now read the screening provision itself. Regulation 16(1) of the PMLTFPF Regulations 2019 (2025 Revised Edition) says:

16.—(1) A regulated dealer must, before dealing with any customer, take reasonable measures to assess whether the customer, any person on whose behalf the customer is acting, or a beneficial owner of the customer (where the customer is an entity or a legal arrangement) is —

(a) a terrorist or terrorist entity under the Terrorism (Suppression of Financing) Act 2002;

(b) a designated person as defined in any regulations made under the United Nations Act 2001; or

(c) a person notified by the Registrar to the regulated dealer as a person to whom the additional measures in paragraph (2) are to apply.

Section 20 of the Act is the hook for it.

There is no threshold in that wording. There is no reference to how the customer pays. There is no amount below which it switches off. MinLaw’s own resources page puts it plainly: dealers are required to screen their customers against the lists before engaging in any business or commercial activity with them.

That is the whole contrast, and it is worth stating slowly, because a dealer can be entirely correct that they have no designated transactions and still be wrong to conclude they need not screen. One provision is attached to a payment method and an amount. The other is attached to the act of dealing with a customer, full stop.

Why the gap exists

This is not carelessness, and it is worth explaining why the mistake is so natural. In the payments world, customer due diligence happens at onboarding, before anyone transacts. Screening rides along with it automatically, because you cannot open the account without doing both.

A precious stones and metals dealer often has no onboarding moment. A customer walks in, buys, and leaves. There is no account, no application form, no single point where checks are bundled together. So nothing carries the screening along. The duty that a bank performs once at account opening has, for a dealer, no obvious moment to attach to, and it quietly falls out of the routine.

A simple way to hold it: screening is a wanted-list check, not a size check. You would not wave someone through a wanted-list check because the purchase was small. The amount was never the point.

When interacting with some of the firms I work with, I keep seeing the same pattern: screening applied only above the S$20,000 line, as though the two duties shared a trigger. They do not. And the stakes are not lopsided in the way that habit assumes. A breach of the screening duty under section 20 carries a maximum fine of S$100,000, the same maximum as a customer due diligence breach under section 16. The obligation dealers treat as optional is penalised exactly the same as the one they take seriously.

The nuance that keeps this practical

There is a fair objection: does this mean running a full screening workflow on every small walk-in sale? No, and the provision itself answers it. Regulation 16(1) asks for “reasonable measures to assess.” The measure is proportionate to the risk. What is not proportionate, and what the wording does not allow, is a transaction value below which the duty disappears.

Say it in one line: the trigger is universal, the method is proportionate. There is no sale small enough to switch the obligation off, but a modest sale does not demand the same depth as a complex corporate one.

That still leaves a fair question: what does reasonable actually look like for a four-person shop? More concretely than the phrase suggests. MinLaw provides a screening module inside its own myPal portal, free to registered dealers, covering the designation lists that matter. Running a customer’s name through it before the sale and saving the result is a defensible answer to the question, and it is difficult to call unreasonable something the regulator built and offered you.

The judgement is not really about whether to look. It is about what you do with a partial match on a common name, which is where a written procedure earns its keep.

The other half of the answer is that reasonable is measured against what you decided and wrote down. A dealer who sets out in their own policy what they screen, when, and what happens on a hit has converted an open question into one with an answer. A dealer who never wrote it down is left arguing about it after the fact.

Getting it right in practice

A few points that decide whether screening is actually done, rather than assumed.

It reaches wider than the person at the counter. Regulation 16 covers the customer, any person the customer is acting for, and, for a company, the beneficial owner behind it. Screening one walk-in’s NRIC does not discharge the duty for a corporate buyer.

The lists are not all the same kind of list. The binding lists, the ones a hit on prohibits you from dealing, are the designation lists: the Inter-Ministry Committee designations, the United Nations lists that MAS publishes, and persons the Registrar notifies you about. The FATF grey and black lists are a different thing. They are jurisdiction risk ratings that feed the risk-based enhanced due diligence in Regulation 7. They never prohibit dealing. Keeping those two apart matters, because treating a country risk rating as a prohibition, or a prohibition as a mere risk factor, are both errors.

If you have reason to suspect a customer is on one of those lists, there are four steps, and the last is the one people miss. Note the trigger: the regulation says reason to suspect, not a confirmed match. A partial name match you cannot rule out is enough to engage it, which is the common case for a dealer holding a name and nothing else. Regulation 16(2) then requires you to decline the transaction, terminate any transaction already entered into, report to the police, and submit a copy of that report to the Registrar at the time of the police report or immediately after. That copy to the Registrar is routinely forgotten, the same two-step we flagged on the cash transaction report in the PSPM guide.

Two further points that the Regulation itself does not carry, but MinLaw’s Guidelines do. Related funds or assets should be frozen immediately, which the Guidelines put at within 24 hours of designation. And a suspicious transaction report must be filed. Sanctions cases do not get the ordinary five business day window either: the Guidelines say reports in these cases are to be filed within one business day, if not immediately.

Tipping off remains prohibited throughout. A dealer must not tell the customer that assets have been frozen or that a report has been filed.

A word on your own internal threshold. Some dealers set a house customer-due-diligence limit, higher or lower than the statutory one. That is a policy choice, not a statutory requirement, and it is worth knowing that a voluntary threshold can create an expectation you then have to meet. Whether to set one is a decision for your own compliance judgement, not something this article should decide for you.

Where this leaves you

The honest summary is short. Your customer due diligence threshold depends on how your customers pay. There is no sanctions screening threshold to match it. If you have been screening only above S$20,000, the gap is not in your effort, it is in a link between two duties that was never really there.

Most dealers are not compliance specialists, and untangling which duty attaches to what is exactly the kind of work that slips until an inspection makes it urgent. That is the gap we built Azentiq Nexus Consulting to close. We help you set up a framework that screens the way the regulation actually reads, and we bring your team up to speed on why, so the understanding stays with you and not just with us.

If you are not certain your current process would hold up, we offer a free 15-minute review. No pressure, just an honest read on where you stand.

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

Read the companion guide: The PSPM Act, Explained.

Also worth reading: what should make you look twice below S$20,000.