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Reporting of Cross Border Movement of Physical Currency and Bearer Negotiable Instruments



Background
1.	Is the reporting of cross border movements of CBNI a form of currency control?
	No. There are no restrictions on the type or amount of CBNI which may be moved into or out of Singapore as long as a person gives a full and accurate report to the authorities when the total value of the CBNI exceeds SGD 30,000 or its equivalent in a foreign currency. back to top


2.	Why is it necessary to implement the reporting of cross border movements of CBNI in Singapore?
	Criminals, in particular transnational crime groups, and terrorism financiers around the world have been known to use cash couriers as a major means of moving physical funds across borders either to finance their illicit activities or to launder their ill-gotten gains. As an active and integrated member of the global economy, Singapore could also be susceptible to such illegal activities. Hence, this initiative is part of Singapore 's overall efforts to combat transnational crime, money laundering and terrorism financing to require the reporting of cross border movements of CBNI. This is also in line with international practices and standards recommended by the Financial Action Task Force, an inter-governmental body that develops and promotes policies to combat money laundering and terrorism financing. Singapore has been a member of FATF since 1991. back to top


3.	Which countries have implemented the reporting of cross border movements of CBNI?
	The countries include the United States , Spain , Canada and Australia. back to top


4.	Is this initiative is meant to combat terrorism financing, then why is the threshold so high? Terrorists do not need significant amount of funds to carry out acts of terrorism.
	Whatever the threshold we adopt, there will be questions on whether it is too high or too low. There is a need to strike a balance between detecting cash couriers, which is a money laundering and terrorism financing vulnerability, and intruding into the privacy of innocent travellers who are carrying CBNI for legitimate purposes. back to top


5.	Why is the threshold currently set at SGD 30,000?
	The threshold of SGD 30,000 (the equivalent of EUR 15,000) is set in accordance with international standards recommended by the FATF. back to top


6.	Which government agency is responsible for enforcing the reporting requirement?
	The Commercial Affairs Department of the Singapore Police Force enforces the reporting requirement in collaboration with other government agencies like the Immigration and Checkpoints Authority. back to top


Definition of Terms
1.	What does it mean to "move into or out of Singapore " CBNI?
	Under the law, a person moves CBNI out of Singapore if the person takes or sends the CBNI (whether in a receptacle or otherwise) out of Singapore while a person moves CBNI into Singapore if the person brings or sends the CBNI (whether in a receptacle or otherwise) into Singapore . The word "send" includes send through the post or by means of another person. back to top


2.	What exactly is physical currency?
	Under the law, "Physical currency" means the coin and printed money (whether of Singapore or of a foreign country) that: a. is designated as legal tender; and b. circulates as, and is customarily used and accepted as, a medium of exchange in the country of issue. back to top


3.	What is a bearer negotiable instrument?
	Under the law, "Bearer negotiable instrument" means - a. a traveller's cheque; or b. any negotiable instrument that is in bearer form, indorsed without any restriction, made out to a fictitious payee or otherwise in such form that title passes upon delivery, and includes a negotiable instrument that has been signed but with the payee's name omitted. back to top


4.	What is a negotiable instrument?
	A negotiable instrument refers to an instrument (such as a bill of exchange, cheque or promissory note) representing a sum of money the title to which can be freely transferred between parties. back to top


5.	What are some examples of bearer negotiable instruments?
	A bearer negotiable instrument includes examples such as bill of exchange, cheque, promissory note, bearer bond, money order and postal order. back to top


6.	Are crossed cheques made payable to account payee only considered bearer negotiable instrument?
	Under the definition of BNI, only a negotiable instrument that is in bearer form, indorsed without any restriction, made out to a fictitious payee or otherwise in such form that title passes upon delivery, or which has been signed but with the payee's name omitted, qualifies as a BNI. As such, a crossed cheque is not a bearer negotiable instrument. On the other hand, a crossed cheque made payable to account payee without the name of the payee being stated or if it is payable to bearer as well, then it would be a bearer negotiable instrument. back to top


7.	Do electronic transactions e.g. telegraphic transfers need to be reported?
	No. The reporting requirement applies only to physical movements of CBNI into and out of Singapore. back to top


8.	Who is an Immigration Officer?
	An Immigration Officer is defined to be the "Controller of Immigration or any immigration officer appointed under section 3 of the Immigration Act, and includes an officer of customs". Generally, this would include an officer of the Immigration and Checkpoints Authority. back to top


9.	Who is a Suspicious Transaction Reporting Officer? How is he different from an Authorised Officer?
	A Suspicious Transaction Reporting Officer is an Authorised Officer who has been appointed by the Minister and gazetted as a Suspicious Transaction Reporting Officer. His role is to receive, analyse and disseminate suspicious transaction reports received from the various reporting entities. back to top


CBNI Report
1.	What are the languages used in the CBNI report form? Are there plans to make the report form available in more foreign languages?
	The CBNI report form is available in 4 languages, namely English, Chinese, Malay and Japanese. This is consistent with the languages used for Singapore Disembarkation / Embarkation Cards. There are no plans at present to make it available in more languages. However, we are open to introducing the report forms in more languages, should the number of visitors from these non-English speaking countries increase. back to top


2.	What is the rationale/purpose of introducing the CBNI report form in four languages?
	This is part of our efforts to create a visitor-friendly environment and enhance the convenience of visitors to Singapore . The CBNI report form in the other three languages will help visitors who are more conversant in Chinese, Malay and Japanese. back to top


3.	Why must the CBNI report be completed in English and not in the respective languages used?
	Filling up the CBNI report in English will help to facilitate immigration clearance as English is the language of administration in Singapore. back to top


4.	What are the basis and/or the determining factors for selecting the languages used for the CBNI report form?
	The language selection consideration for the CBNI report form is based on the demand for them. An indication of such demand will be the number of visitors from these non-English speaking countries. back to top


5.	Why are there two different CBNI report forms for submissions, one for Traveller and the other for Sender or Recipient of CBNI? What is the difference?
	The two types of report forms are designed to cater for the key modes of movements of CBNI into or out of Singapore. The CBNI Report (Traveller) is used by travellers entering or leaving Singapore. The CBNI Report (Sender, Carrier or Recipient) is used by those sending CBNI out of Singapore or receiving CBNI in Singapore. back to top


6.	Will the two types of CBNI report form be in the English language only?
	Each of the two types of CBNI report forms is available in 4 languages. The languages are English, Chinese, Malay and Japanese. back to top


7.	Where can one obtain the CBNI report forms?
	The CBNI report forms are available at all checkpoints, police establishments, Singapore Visitors Centre and branches of Singapore Post. It will also be available for download at the websites of the Singapore Police Force and the Commercial Affairs Department. The report forms can also be obtained on board flights, ferries and cruise ships. back to top


8.	What kind of information do I need to provide in the CBNI report?
	The information required includes the particulars of the person giving the report as well as the type, amount, movements of the CBNI and the reason for the movement. If you send or receive CBNI, you should retain the supporting documents like invoices, acknowledgement receipts, etc, for a reasonable period in the event the authorities require them to be produced for investigation. back to top


9.	Will I receive a copy or acknowledgement receipt of the CBNI report that I have submitted?
	You will not be given a copy of the completed CBNI report or an acknowledgement receipt. back to top


10.	Where should I obtain the exchange rate to translate foreign-denominated CBNI into Singapore dollars?
	In determining whether an amount of foreign currency (including an amount in which a document is denominated) is equivalent to a Singapore dollar amount, the amount of foreign currency is to be translated to Singapore currency at the exchange rate applicable at the relevant time. As the Singapore dollar is a freely traded currency, there is no officially prescribed exchange rate. Indications of prevailing exchange rates may be obtained from major newswires, banks and websites such as Monetary Authority of Singapore and Singapore Customs. back to top


Reporting
1.	Is it true that only Singapore dollar denominated CBNI have to be reported?
	No. All CBNI, whether in Singapore dollars or in a foreign currency, must be reported if their total value exceeds SGD 30,000 or its equivalent in a foreign currency. back to top


2.	Does the reporting of cross border movements of CBNI apply to Singaporeans?
	Yes. All persons who move CBNI exceeding SGD 30,000 or its equivalent in a foreign currency into or out of Singapore are required to report. back to top


3.	If an employee collects CBNI on his company's behalf and carries it into Singapore and then hands it over to the company, would both the employee (as a traveller) and the company (as a recipient) have to report? Since the employee could be regarded as an agent or a part of the company, why must the company separately report receipt of the CBNI?
	The employee (as a traveller) and the company (as a recipient) will have to report. In this case, the employee makes a report in his personal capacity for moving CBNI into Singapore . The company is a separate legal entity and it is therefore required to give a report as the recipient of the CBNI. back to top


4.	If an employee receives CBNI from outside Singapore on his company's behalf, but neglects to make a give a report, who will be held liable - the employee or his company? Either way, would it be fair?
	The employee would be held liable for failure to give a report. The company would be liable if the receipt by the employee was done within his actual or apparent authority. back to top


5.	Do I have to give a report if I am moving CBNI exceeding the prescribed amount into Singapore but I do not intend to use it in Singapore or give it to a recipient in Singapore ?
	Yes. A person needs to give a report as long as he is physically moving CBNI exceeding the exceeding SGD 30,000 or its equivalent in a foreign currency into or out of Singapore. back to top


6.	I am a sender or recipient of CBNI. How do I submit the CBNI report to a Suspicious Transaction Reporting Officer?
	You can submit the CBNI report by hand or by post to the Commercial Affairs Department, Suspicious Transaction Report Office at 391, New Bridge Road , #06-701, Police Cantonment Complex, Singapore 088762. You can reach our office at +65 6557 5480. back to top


7.	Can I submit the CBNI report by fax?
	Yes, the fax number is +65 6223 6603. However, you are still required to send the original report by hand or by post as the original report is required for evidential purposes. If you send CBNI out of Singapore , the report must reach STRO at least one business day before the sending. Persons who receive CBNI from outside Singapore will be required to submit the report to STRO within five business days upon receipt. A business day is defined as a day other than Saturday, Sunday or public holiday. back to top


8.	Are on-line submissions of CBNI report allowed?
	On-line submission of the CBNI report is under consideration by the Commercial Affairs Department back to top


9.	Can I submit CBNI report on a duplicated or photocopied CBNI report form?
	Yes. However, the report will have to be in the prescribed format and must be duly signed by the person giving the report. back to top


10.	What happens if I submit the CBNI report late to the Suspicious Transaction Reporting Officer?
	The recipient needs to submit his CBNI report to a Suspicious Transaction Reporting Officer within 5 business days, the failure of which is an offence under the law. A "business day" is defined as a day other than a Saturday, Sunday or Public Holiday. back to top


Traveller
1.	Does a commercial carrier (e.g. airline or cruise operator) have to give a CBNI report on behalf of their passengers who are moving CBNI above SGD 30,000 or its equivalent in a foreign currency?
	The commercial carrier is not required to give a report if the CBNI is in the possession of the carrier's passenger. back to top


2.	Will a person have to give a CBNI report if he gets another person to carry part of his cash, say SGD 50,000, such that each person carries less than SGD 30,000?
	Both persons may be liable for an offence of having common intention or abetment by conspiracy to carry more than SGD 30,000 into or out of Singapore. back to top


3.	Will a child have to give a CBNI report if he is carrying CBNI above SGD 30,000 or its equivalent in a foreign currency?
	A child 7 years or younger is not required to make a report. However, in such cases, the parent or guardian travelling with the child will have to give a report on his behalf. The failure to do so can constitute an abetment offence. For all practical purposes, a child would not be carrying SGD 30,000 or more unless this had been given to him by an adult. The adult would not be able to circumvent the law by requesting a child to carry his CBNI. As such, the adult would still be required to give a report if he had given the child the CBNI. back to top


4.	Can I give a report if I am not sure of the total amount of CBNI that I am carrying?
	Yes. Alternatively, you can approach any Immigration Officer for clarification or call the Suspicious Transaction Reporting Office at +65 6557 5480 (available 24/7) for assistance. You can also visit the Singapore Police Force's website for more information. back to top


5.	What is the punishment if I fail to give a CBNI report?
	A person found guilty of a failure to give a report shall be liable on conviction to a fine not exceeding SGD 50,000 or to imprisonment for a term not exceeding 3 years or to both. back to top


6.	Is it an offence if a person gives a false CBNI report?
	Yes. A person found guilty for not giving a full and accurate report shall be liable on conviction to a fine not exceeding SGD 50,000 or to imprisonment for a term not exceeding 3 years or to both. back to top


7.	Where and how do I submit the report? What if there is no Customs Red Channel at my disembarkation point?
	There are Customs Red Channels at most of the checkpoints for incoming travellers. You should seek help from any Immigration Officer nearby for the location of the Customs Red Channel at these checkpoints. You can hand the report to any Immigration Officer at the Immigration Counter if there is no Customs Red Channel. Outgoing travellers, on the other hand, have to submit their CBNI reports to the Immigration Officer at the Immigration Counter before departing Singapore . Adequate publicity materials will be placed at the checkpoints to assist you. back to top


8.	Will there be any assistance for travellers to fill in the CBNI report forms?
	A guide on the filling up of the CBNI report form will be available at the checkpoints. You can approach any Immigration Officer for clarification or call the Suspicious Transaction Reporting Office at +65 6557 5480 (available 24/7) for assistance. You can also visit the Singapore Police Force's website for more information. [Note: The guide will be placed at the Singapore Disembarkation / Embarkation Card filling in counters. The guide will also be available at the SPF website.] back to top


9.	Do transit travellers need to give a report if they have CBNI exceeding SGD 30,000 or its equivalent in a foreign currency?
	Transit travellers do not need to give a report as long as they do not enter Singapore with the CBNI through immigration clearance. back to top


10.	I am travelling from another country to Singapore with CBNI exceeding SGD 30,000. If I had already given a report on the CBNI at the country which I departed from, must I still give a report when I arrive in Singapore ?
	Yes. You still need to give a report under Singapore law. back to top


Cargo & Postal Courier
1.	Does a courier/transport company have to give a CBNI report on behalf of their customers who are moving CBNI above SGD 30,000 or its equivalent in a foreign currency?
	The courier/transport company is not required to give a CBNI report if the CBNI is: a. carried on behalf of another person and the other person has not disclosed to the courier/transport company that the goods carried on behalf of the other person includes CBNI; and b. that courier/transport company does not know, and has no reasonable grounds to believe that the goods carried on behalf of the other person include CBNI. However, a courier/transport company would have to give a CBNI report if it is aware that it is carrying CBNI exceeding SGD 30,000 or its equivalent in a foreign currency, for its clients. back to top


2.	Would a Tradenet declaring agent have to give a CBNI report if he is aware that his customer is moving CBNI above SGD 30,000 or its equivalent in a foreign currency, into or out of Singapore?
	There is no requirement for the Tradenet declaring agent to give a report if he is not the one moving or attempting to move the CBNI into or out of Singapore . It would be the responsibility of the agent's customer to ensure that the report is made to the authorities. back to top


3.	Does a person have to give a report if he is importing CBNI above SGD 30,000 or its equivalent in a foreign currency?
	Yes. back to top


4.	Can a CBNI report be given prior to the movement of the CBNI into or out of Singapore?
	The CBNI report can be pre-filled and handed to the authorities. If you are moving CBNI into or out of Singapore, the total value of which exceeds SGD 30,000 or its equivalent in a foreign currency, you are required by law to give a report to the STRO no later than one business day (or, if the report is to be sent by post, no later than two business days) prior to the moving of the CBNI or if it is not reasonably practicable to do so, you should give the report to the STRO at the first opportunity thereafter but before the CBNI is moved into or out of Singapore. back to top


5.	What happens if I gave a prior CBNI report to the authorities but the CBNI was eventually not moved into or out of Singapore?
	You must inform the authorities of the change in situation as soon as practicable. The failure to do so could constitute the making of a false report. back to top


6.	I am a shipping agent. I do not perform immigration clearance to leave Singapore when I board a vessel within the Singapore Territorial Waters to pass CBNI to the crew for purposes like ship cash, salary payment, etc. Do I need to give a report?
	There is no reporting obligation for shipping agents under such circumstances when they move CBNI to vessels within the Singapore Territorial Waters. back to top


Recipient
1.	Why does this requirement to report apply only to the first recipient?
	There must be a limit to the extent in which recipients of CBNI would have to give a report. It would not be reasonable for everyone who received CBNI to enquire about whether the CBNI was recently brought into Singapore . Subsequent movement of the CBNI within Singapore would not constitute the movement of CBNI into or out of Singapore . The CBNI is already in Singapore. back to top


2.	What situations are envisaged regarding instances where the recipient of CBNI has reasonable grounds to believe that such CBNI has been moved to him from outside Singapore?
	a. A person who receives CBNI (exceeding the prescribed threshold of SGD 30,000) from overseas through the postal service. b. A person who causes the CBNI (exceeding the prescribed threshold of SGD 30,000) to be delivered from overseas and receives it from a courier that has just entered Singapore . c. A person wants to change a large quantity of foreign currency (exceeding the prescribed threshold of SGD 30,000) into Singapore currency or another currency. The money changer who records the person's particulars (as required under the Money Changers and Remittance Businesses Act) notes from his passport that he has just entered Singapore . The recipient is only required to report if he had actual or constructive knowledge that he was in receipt of CBNI that was moved into Singapore . The recipient is not required to verify or investigate whether the CBNI was moved into Singapore . There is also no requirement to report if the CBNI was obtained from local sources e.g. withdrawal from another bank, or receipts from local business. back to top


3.	Would the mere fact that the holder of CBNI is a foreigner mean that the recipient of CBNI would have to give a report?
	If the recipient did not know that the CBNI had physically moved into Singapore , and that he is the first recipient, there would be no need for him to report merely on the basis that the holder of CBNI is a foreigner. There are many foreigners who reside and work in Singapore and the CBNI may have been obtained domestically. back to top


Industry
1.	Some foreign clients bring in CBNI to make payments to local companies. If the CBNI is a bank draft with the local company named as the payee, is it subject to the reporting requirement?
	The bank draft is subject to the reporting requirement if the bank draft falls under the definition of BNI. back to top


2.	Some foreign clients may bring into Singapore CBNI exceeding SGD 30,000 where part of which is for payment in Singapore and the other part is for payment in other countries that the foreign clients are going to subsequently. Do the foreign clients need to report on the part payable in other countries?
	Yes. The part payable in other countries needs to be reported since it has been brought into Singapore. back to top


3.	Will the reporting of cross border movements of CBNI affect genuine businesses in Singapore since the foreign clients sometimes transact in large amounts of cash?
	This initiative is not a currency control measure. There are no restriction s on the type or amount of CBNI a person can move into or out of Singapore as long as he gives a full and accurate report to the authorities. back to top


Punishment And Enforcement
1.	What are the offences under the CBNI reporting requirement?
	The offences include a failure to give a report, a failure to provide full and accurate information and a failure to give the report in the prescribed form. back to top


2.	What is the Suspicious Transaction Reporting Office and the powers of a Suspicious Transaction Reporting Officer?
	The Suspicious Transaction Reporting Office is the Financial Intelligence Unit of Singapore. Its role in the CBNI reporting regime is to receive, collate and analyse information contained in the CBNI report. The Suspicious Transaction Reporting Officer is an officer of the Suspicious Transaction Reporting Office and he is authorised under the law to collect the CBNI report. back to top


3.	Will there be a leniency or grace period for "innocent" offenders who may not be familiar with the procedures?
	No grace period will be given. The public will be adequately informed of the new CBNI reporting requirement and of their obligations under the law. There will be reminders placed strategically at the various checkpoints to remind travellers of their reporting obligations. A reminder would be included in the Singapore Disembarkation / Embarkation Card to remind overseas travellers of their obligations. back to top


4.	What if a person is unaware of the reporting requirement, or forgets to report? The punishment of SGD 50,000 fine or up to 3 years imprisonment, or both, seems too harsh.
	There will be adequate publicity on the reporting requirement at all incoming and outgoing checkpoints. Law enforcement will be circumspect and will take into account the possibility that a person may not have wilfully failed to give a report. In such instances, the full force of the law will not be used against such persons. We will only prosecute in cases where it is clear that the law was wilfully breached. back to top


5.	How will checks be made to verify that the CBNI report is true? Who will be doing the checks?
	Verification of the reported amount will be carried out by an Immigration Officer in the presence of the traveller. It shall be conducted in a suitable room where privacy is assured and witnessed by another officer. Female suspects will only be searched by female officers. back to top


6.	What about travellers carrying high value items like gold, gems and precious metals? Are they not risks of money laundering or terrorism financing? What action will be taken?
	Travellers carrying high value items that are not CBNI are not required to give a CBNI report. However, if there are suspicions that such persons are engaging in illicit activities in Singapore , appropriate action will be taken. back to top

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Last reviewed on 16 August, 2010

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