PSPM Act Singapore: Registration Guide for Jewellers, Watch Dealers & Precious Metals Businesses

Why Watch Dealers and Jewellers Can't Ignore the PSPM Act

If you sell watches with gold cases, jewellery with diamonds, or any precious metals above S$20,000, you're a "regulated dealer" under Singapore's Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019. Operating without registration exposes you to fines up to S$75,000 and imprisonment up to 3 years.

This guide breaks down everything you need to know: Class A versus Class B registration, the S$20,000 threshold that triggers compliance, customer due diligence requirements, cash transaction reporting, and the practical steps to get registered through GoBusiness.

Here's what you'll find:

• Who must register (the "regulated dealer" definition)
• Class A vs Class B registration and fees
• The S$20,000 threshold explained
• Customer Due Diligence (CDD) requirements
• Cash Transaction Report (CTR) and Suspicious Transaction Report (STR) obligations
• May 2024 amendments you need to know
• Step-by-step registration process
• Real enforcement cases and penalties

What is the PSPM Act?

The Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019 came into force on 10 April 2019. It's Singapore's implementation of Financial Action Task Force (FATF) standards for the precious goods sector. The Act was significantly amended on 1 May 2024 to expand coverage and strengthen enforcement.

The rationale is straightforward. Precious stones and metals have high commercial value, are portable, and convert easily to cash. These characteristics make them attractive for money laundering and terrorism financing. The PSPM Act ensures dealers implement controls to detect and report suspicious activity.

Aspect	Details
Full Name	Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019
Effective Date	10 April 2019
Major Amendments	1 May 2024 (Act 6 of 2024)
Regulatory Authority	Ministry of Law, Anti-Money Laundering/Countering the Financing of Terrorism Division (ACD)
Purpose	Combat money laundering, terrorism financing, and proliferation financing through the precious goods sector

Who Must Register as a Regulated Dealer?

The Act defines "regulated dealer" broadly. If you carry on a business of "regulated dealing" or act as an intermediary for such dealing, you must register. This catches more businesses than many realise.

What Counts as Regulated Dealing?

Activity	Covered?
Selling precious stones, metals, or products	Yes
Offering precious items for sale	Yes
Purchasing precious items for resale	Yes
Importing precious items for sale	Yes
Manufacturing precious items	Yes
Possessing precious items for sale	Yes
Selling or redeeming asset-backed tokens	Yes
Operating as auction house for precious items	Yes (intermediary)
Running trading platform for precious items	Yes (intermediary)

Business Types That Must Register

Business Type	Registration Required?	Notes
Pre-owned watch dealer (gold/platinum watches)	Yes	Precious metal cases trigger coverage
Pre-owned watch dealer (steel only)	Maybe	If any watch exceeds S$20,000, yes
Jewellery retailer	Yes	Diamonds, gold, precious stones
Bullion trader	Yes	Gold, silver, platinum bars/coins
Jewellery wholesaler	Yes	B2B dealing still counts
Secondhand goods dealer (precious items)	Yes	In addition to SHGD licence
Auction house (watches/jewellery)	Yes	Intermediary for regulated dealing
Pawnbroker	No	Covered under Pawnbrokers Act instead
MAS-regulated financial institution	No*	*Still must file CTRs

What Are "Precious Stones", "Precious Metals", and "Precious Products"?

The Act defines these terms specifically. Understanding them helps you determine whether your inventory triggers registration requirements.

Precious Stones

Stone Type	Covered?
Diamonds	Yes
Sapphires	Yes
Rubies	Yes
Emeralds	Yes
Jade (nephrite and jadeite)	Yes
Pearls	Yes

Precious Metals

Metal Type	Covered?
Gold	Yes
Silver	Yes
Platinum	Yes
Iridium	Yes
Osmium	Yes
Palladium	Yes
Rhodium	Yes
Ruthenium	Yes
Alloys with ≥2% precious metal content	Yes

Precious Products (The S$20,000 Threshold)

This is where it gets important for watch dealers. A "precious product" means jewellery, watches, apparel, accessories, or other finished products that meet either criterion:

Criterion	What It Means
50% Rule	Derives 50% or more of its value from precious stones or metals
S$20,000 Rule	Net price exceeds S$20,000, regardless of precious content

The May 2024 amendments clarified that items above S$20,000 are covered "regardless of the value attributable to the precious stones or metals." This means a steel Rolex Daytona selling for S$25,000 triggers PSPM coverage even though it contains no precious metals.

Watch Dealer Implications

Watch Type	PSPM Registration Required?	Why
Gold Rolex Day-Date (any price)	Yes	Gold case = precious metal
Platinum Patek Philippe	Yes	Platinum = precious metal
Diamond-set bezel (any base)	Yes	Diamonds = precious stones
Steel Rolex Daytona at S$25,000	Yes	Price exceeds S$20,000
Steel Rolex Submariner at S$15,000	No	No precious content, under S$20,000
Tudor Black Bay at S$5,000	No	No precious content, under S$20,000

Class A vs Class B Registration

The PSPM Act creates two registration tiers based on the maximum value of items you sell. This determines your annual fee and compliance scope.

Aspect	Class A	Class B
Item Price Limit	Under S$2,000 per item	Unlimited
Annual Fee (per outlet)	S$250	S$350
Application Fee	S$120	S$120
Best For	Fashion jewellery, low-value items	Watch dealers, fine jewellers
CDD Required?	Yes (for designated transactions)	Yes (for designated transactions)
CTR Filing?	Yes (if cash >S$20,000)	Yes (if cash >S$20,000)

Important: All outlets owned by a registered dealer must be on the same registration tier. You cannot have one outlet on Class A and another on Class B.

Which Class Do Watch Dealers Need?

Almost every pre-owned watch dealer needs Class B registration. Even if you primarily deal in steel sports models, the moment you handle a single gold Rolex or a steel piece priced above S$2,000 (which is most luxury watches), you need Class B.

Your Inventory	Class Needed
Only fashion watches under S$2,000	Class A (S$250/outlet/year)
Any luxury watch (even steel Tudor at S$3,000)	Class B (S$350/outlet/year)
Mixed inventory (low and high value)	Class B (S$350/outlet/year)
Fine jewellery retailer	Class B (S$350/outlet/year)

Registration Fees Breakdown

Understanding the full cost helps you budget correctly. Fees are per outlet and per year.

Fee Type	Amount	Notes
Application Fee	S$120	One-time, per entity, non-refundable
Class A Registration	S$250/outlet/year	Items under S$2,000 only
Class B Registration	S$350/outlet/year	Unlimited item values

Total First-Year Cost Examples

Scenario	Calculation	Total
Single outlet, Class B	S$120 + S$350	S$470
Two outlets, Class B	S$120 + (S$350 × 2)	S$820
Single outlet, Class A	S$120 + S$250	S$370
Three outlets, Class B	S$120 + (S$350 × 3)	S$1,170

No GST applies to these fees.

The S$20,000 Threshold: Why It Matters

S$20,000 is the key number in PSPM compliance. It triggers multiple obligations beyond just registration.

Threshold	What It Triggers
Item price >S$20,000	Item becomes "precious product" regardless of materials
Cash payment >S$20,000	Designated transaction requiring CDD and CTR
Multiple cash transactions same day >S$20,000 total	Must aggregate; triggers CTR if threshold crossed

Designated Transactions: When Compliance Kicks In

Not every sale requires CDD and CTR filing. Only "designated transactions" trigger these obligations. Understanding what counts as a designated transaction is crucial.

Transaction Type	Designated?	Requirements
Sale for cash/cash equivalent >S$20,000	Yes	CDD + CTR
Multiple sales to same customer, same day, cash >S$20,000 total	Yes	CDD + CTR
Purchase from customer for cash >S$20,000 (secondhand dealer)	Yes	CDD + CTR
Sale for digital payment token >S$20,000	Yes	CDD + CTR
Asset-backed token redemption >S$20,000	Yes	CDD + CTR
Sale by credit card (any amount)	No	No CDD/CTR required
Sale by bank transfer (any amount)	No	No CDD/CTR required

What Counts as "Cash or Cash Equivalent"?

Payment Type	Cash Equivalent?
Physical currency (notes/coins)	Yes
Cashier's order	Yes
Money order	Yes
Traveller's cheque	Yes
Personal cheque	Yes
Bank draft	Yes
Digital payment token (cryptocurrency)	Yes
Credit card	No
Bank transfer/GIRO	No
PayNow	No

Customer Due Diligence (CDD) Requirements

For every designated transaction, you must conduct Customer Due Diligence before completing the sale. This isn't optional; failure to perform CDD carries penalties up to S$100,000.

What CDD Involves

CDD Element	What You Must Do
Customer Identification	Obtain full name, date of birth, nationality, residential address
Verification	Verify identity using reliable documents (NRIC, passport)
Beneficial Ownership	Identify who ultimately owns/controls the transaction
Purpose Assessment	Understand the purpose and intended nature of the transaction
Source of Funds	For large transactions, understand where the money comes from

Enhanced Customer Due Diligence (ECDD)

When you identify higher ML/TF/PF risks, you must implement Enhanced CDD measures. Triggers include:

• Politically Exposed Persons (PEPs) or their family/associates
• Customers from high-risk jurisdictions
• Complex or unusually large transactions
• Unusual patterns without apparent economic purpose
• Anything that raises suspicion

When You Cannot Complete CDD

Critical rule: If you cannot perform or complete required CDD, you must not proceed with the transaction. Terminate the transaction and consider filing a Suspicious Transaction Report (STR).

Cash Transaction Report (CTR) Filing

Every designated transaction requires filing a Cash Transaction Report with the Suspicious Transaction Reporting Office (STRO) within 15 business days.

CTR Requirement	Details
Threshold	Cash/cash equivalent exceeding S$20,000
Filing Deadline	Within 15 business days of transaction
Filing Method	Electronically via SONAR system
Record Retention	Keep copy of filed CTR for 5 years
Aggregation	Must combine multiple transactions to same customer on same day

SONAR System Access

You must apply for a STRO Online Notices and Reporting (SONAR) account to file CTRs electronically. When you file via SONAR, a copy is automatically shared with ACD.

Suspicious Transaction Report (STR) Filing

Beyond CTRs, you must file a Suspicious Transaction Report whenever you suspect money laundering, terrorism financing, or proliferation financing. There's no minimum threshold; suspicion alone triggers the requirement.

STR Aspect	Details
Trigger	Suspicion of ML/TF/PF (no minimum amount)
Filing Method	Via SONAR system
Tipping Off	Offence to tell anyone you've filed an STR
Legal Protection	Good faith filing provides legal protection

Warning: It's a criminal offence under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act to tip off any person about an STR you've filed with STRO.

Record-Keeping Requirements

The PSPM Act mandates comprehensive record-keeping. These records support audit trails and investigations.

Record Type	Retention Period
Customer identification records	5 years after transaction/relationship ends
Transaction records	5 years after transaction date
CDD documentation	5 years after transaction
Filed CTR copies	5 years after submission
Internal compliance documents	5 years after creation

The May 2024 amendments extended record-keeping obligations to a prescribed period after ceasing operations. You can't destroy records just because you've closed the business.

May 2024 Amendments: Key Changes

The PSPM Act was significantly amended effective 1 May 2024. These changes affect watch dealers and jewellers.

Amendment	Impact
Expanded scope to "Proliferation Financing"	Act now covers weapons proliferation, not just ML/TF
S$20,000 threshold clarified	Items above S$20,000 covered regardless of precious content
Digital payment tokens excluded	Clearer boundary for crypto; handled under other regulations
Compliance officer vetting	Appointed officers must be assessed as "fit and proper"
New offence: incomplete/inaccurate CTR	Penalties for filing CTRs without reasonable care
Extended record-keeping post-closure	Can't destroy records when business closes
Registration auto-lapses on dissolution/death	No need to formally cancel in these circumstances
Digital service of documents	ACD can now serve notices electronically

Step-by-Step Registration Process

Registration is handled through the GoBusiness portal. Here's what to expect.

Step	Action	Notes
1	Access GoBusiness Dashboard	dashboard.gobusiness.gov.sg
2	Log in with Singpass	Must be director/partner/manager
3	Search for PSPM registration	"Precious Stones and Precious Metals Dealers"
4	Complete application form	Business details, outlets, product types
5	Provide personnel information	Directors, compliance officer, outlet managers
6	Upload documents	ID copies, corporate documents
7	Pay application fee	S$120 (non-refundable)
8	Submit application	Receive acknowledgment
9	ACD reviews application	~4 weeks processing
10	Receive in-principle approval	Notification via GoBusiness
11	Pay registration fee	Within 30 days via GoBusiness
12	Registration certificate issued	You're now a registered dealer

Payment Deadline Warning

You have 30 calendar days to pay the registration fee after receiving in-principle approval. If you miss this deadline, the approval lapses and you must restart the application.

Documents Required

Document	Who Provides	Notes
NRIC copy (Singapore citizens/PR)	Directors, partners, managers, shareholders	Front and back
Passport copy (foreigners)	Foreign directors, partners, managers	Bio-data page
Corporate registration documents	Corporate shareholders	For multi-layer ownership
Organisational chart	Complex ownership structures	Show individual beneficial owners
Compliance officer details	Applicant	Must be "fit and proper" person
Outlet addresses	Applicant	All physical locations

Penalties for Non-Compliance

The PSPM Act carries serious penalties. MinLaw actively enforces compliance through inspections and investigations.

Offence	Maximum Penalty
Operating without registration	Fine up to S$75,000 and/or imprisonment up to 3 years
Failure to perform CDD	Fine up to S$100,000
Failure to file CTR	Fine up to S$20,000
Filing incomplete/inaccurate CTR	Fine (amount varies)
Failure to keep records	Fine up to S$100,000
Tipping off about STR	Criminal offence under CDSA
AML/CFT compliance failures (general)	Composition sums up to S$210,000+ per party

Real Enforcement Cases

MinLaw has taken action against dealers who failed to comply. These cases illustrate the real consequences of non-compliance.

Singapore Precious Metals Exchange Case (2022-2024)

Aspect	Details
Dealer	Singapore Precious Metals Exchange Pte Ltd (SPME)
Business	Gold/silver bullion online store and trading platform
Breach Period	2019-2022
Violations	Failed to identify/assess ML/TF risks; failed to assess risk before new business practices; failed to perform ECDD; failed to conduct ongoing transaction monitoring
Penalty (Company)	S$210,000 composition sum
Penalty (CEO)	S$210,000 composition sum
Total	S$420,000
Status	Paid; implementing remedial actions

Jeweller Charged for CDD Failures (May 2024)

Aspect	Details
Charges Filed	7 May 2024
Violation	Failed to perform CDD despite having reason to suspect ML
Incidents	3 occasions between September-October 2023
Context	Transactions linked to phishing scam proceeds
Transaction Value	Over S$313,000 (gold jewellery and gold bar)
Potential Penalty	Fine up to S$100,000

PSMD Fined for Missing CTR

Aspect	Details
Violation	Failed to submit Cash Transaction Report
Fine	S$9,000

Exemptions from Registration

Certain entities are exempt from PSPM registration, though some must still file CTRs.

Entity Type	Registration Exempt?	CTR Filing?
Pawnbrokers (Pawnbrokers Act)	Yes	No (separate regime)
MAS-regulated financial institutions	Yes	Yes (still required)
Foreign dealers (≤90 days/year in SG)	Yes	Yes (CDD, records, CTR, STR still apply)
Individuals selling personal items	Yes	No (not regulated dealers)

PSPM vs SHGD: Understanding Both Requirements

Watch dealers and jewellers often need both PSPM registration and a Secondhand Goods Dealer's Licence. These are separate regimes administered by different agencies.

Aspect	PSPM Registration	SHGD Licence
Regulatory Authority	MinLaw (ACD)	Singapore Police Force
Focus	Anti-money laundering	Stolen goods prevention
Trigger	Precious content or >S$20,000 value	Dealing in scheduled goods (watches, jewellery)
Annual Cost (Class B, 1 outlet)	S$350	~S$140 (2-year licence)
Key Obligations	CDD, CTR, STR, AML policies	SHOTS transaction records

After Registration: Ongoing Compliance

Registration is the beginning, not the end. Maintaining compliance requires ongoing effort.

Obligation	Frequency	Notes
Renew registration	Annually	Before expiry
Conduct CDD	Every designated transaction	Before completing transaction
File CTRs	Within 15 business days of transaction	Via SONAR
File STRs	When suspicion arises	No delay
Maintain records	Ongoing	5-year retention minimum
Update AML policies	As regulations change	Review annually at minimum
Train staff	Regular intervals	Document training provided
Notify changes	When changes occur	New outlets, directors, addresses

From Compliance to Protection

The compliance process forces you to document something dealers often overlook: the true value of inventory at any given time. CDD records, transaction histories, and CTR filings create a paper trail that quantifies what's in your safe and display cases.

This documentation serves a second purpose beyond regulatory compliance. When you apply for jewellers block insurance, underwriters want to know exactly what you're protecting. The records you keep for PSPM compliance answer their questions. Many dealers discover during compliance setup that their inventory value significantly exceeds their insurance coverage, or that they have no coverage at all.

Getting registered is the foundation. Protecting what you're registering to sell is the logical next step.

Frequently Asked Questions

Do I need PSPM registration if I only sell steel watches?

It depends on price. If any steel watch you sell exceeds S$20,000, you need registration. The May 2024 amendments clarified that items above S$20,000 are covered "regardless of precious content." A steel Rolex Daytona at S$25,000 triggers the requirement.

What's the difference between Class A and Class B?

Class A limits you to items under S$2,000 each and costs S$250/outlet/year. Class B allows unlimited values and costs S$350/outlet/year. Most watch dealers and fine jewellers need Class B.

Can I have different outlets on different classes?

No. All outlets owned by a registered dealer must be on the same registration tier. If one outlet sells items over S$2,000, all outlets must be Class B.

What triggers a Cash Transaction Report?

Cash or cash equivalent payments exceeding S$20,000 for precious items. This includes physical cash, cheques, money orders, and cryptocurrency. Credit cards and bank transfers don't trigger CTRs.

How quickly must I file a CTR?

Within 15 business days of the transaction. Late filing is an offence; one dealer was fined S$9,000 for failing to submit.

What if a customer refuses to provide identification for CDD?

You cannot complete the transaction. The law is clear: if you cannot perform CDD, you must terminate the transaction. Consider whether to file a Suspicious Transaction Report.

Does PSPM registration replace the SHGD licence?

No. These are separate requirements. Most watch and jewellery dealers need both: PSPM registration from MinLaw and SHGD licence from SPF. They serve different purposes (anti-money laundering vs stolen goods prevention).

What happens if I'm caught operating without registration?

Maximum penalty is a fine up to S$75,000 and/or imprisonment up to 3 years. MinLaw actively enforces compliance and has imposed six-figure composition sums on violators.

How long does registration take?

Approximately 4 weeks for processing, plus up to 30 days to pay the registration fee after in-principle approval. Total timeline is roughly 6-8 weeks if everything goes smoothly.

Do I need a compliance officer?

Yes. You must appoint a compliance officer who is assessed as "fit and proper" by the Registrar. This person oversees your AML/CFT policies and procedures.

Application Checklist

Item	Status
Determined if registration required (precious content or >S$20,000)	☐
Identified correct class (A or B)	☐
Listed all outlets to be registered	☐
Gathered director/partner/shareholder details	☐
Prepared NRIC/passport copies	☐
Appointed compliance officer	☐
Prepared organisational chart (if complex ownership)	☐
S$120 application fee ready	☐
Registration fee budget (S$250 or S$350 × outlets)	☐
Applied for SONAR account (for CTR/STR filing)	☐

Key Contacts

Agency	Purpose	Contact
MinLaw ACD	PSPM registration queries	acd.mlaw.gov.sg
GoBusiness	Application portal	dashboard.gobusiness.gov.sg
STRO	CTR/STR filing (SONAR)	police.gov.sg
Singapore Statutes Online	Full text of PSPM Act	sso.agc.gov.sg

Summary

The PSPM Act requires registration for anyone dealing in precious stones, precious metals, or items above S$20,000. For watch dealers and jewellers, this means Class B registration at S$350 per outlet annually, plus ongoing CDD, CTR, and STR obligations.

The May 2024 amendments expanded coverage and strengthened enforcement. MinLaw has demonstrated willingness to impose substantial penalties; the Singapore Precious Metals Exchange case resulted in S$420,000 in composition sums.

Registration takes approximately 4-8 weeks through GoBusiness. Beyond compliance, the documentation process helps dealers understand the true value of their inventory, which is exactly what insurers need when underwriting jewellers block coverage.