Jewellery Shops Selling Online: PSPM Registration and AML Duties

Are you a regulated dealer under the PSPM Act?

The Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019, the PSPM Act, is run by the Ministry of Law's Anti-Money Laundering / Countering the Financing of Terrorism Division (ACD). A regulated dealer is anyone carrying on a business of selling, offering for sale, buying for resale, importing for sale or making precious stones, metals or products, or acting as an intermediary such as a trading platform (MinLaw ACD: Regulatory regime).

MinLaw's examples include jewellers, bullion traders, jewellery wholesalers and retailers, secondhand goods dealers, auction houses and trading platforms. Pawnbrokers and MAS-regulated entities are exempt, as are foreign dealers trading here for no more than 90 days a year (though they must still meet transaction-based rules). Individuals making a one-off sale of their own items are not covered.

MinLaw registration: classes, fees and timeline

MinLaw says you must be registered before you start any regulated dealing, and that dealing unregistered can lead to a fine of up to S$75,000 and/or up to three years' imprisonment (MinLaw ACD: Registration).

Apply through GoBusiness with your company's Corppass and UEN, one application per UEN with all outlets listed. MinLaw says processing takes around four weeks. You will declare details for directors, partners, managers, the company secretary and substantial shareholders, including any history of fraud, money laundering, insolvency or lawsuits.

Cash transaction reports and customer due diligence

The core AML duties are triggered by cash. MinLaw's transaction-based requirements define a designated transaction as a sale for which cash or a cash equivalent exceeding S$20,000 is received, including two or more sales to the same customer in a single day that together exceed S$20,000.

• Customer due diligence (CDD): obtain, record and verify the customer's identity before completing a designated transaction. If you cannot complete CDD, do not proceed, and consider filing a suspicious transaction report.
• Enhanced CDD where the money laundering risk is higher.
• Cash Transaction Report (CTR): file with the Suspicious Transaction Reporting Office through SONAR within 15 business days, and keep a copy for five years.
• Suspicious Transaction Report (STR): file whenever you suspect money laundering, terrorism financing or proliferation financing, regardless of amount or payment method.
• Screening: subscribe to MAS and MHA lists of designated individuals and entities, and stop the transaction and report to the police if a customer matches.

For a typical online store taking cards, PayNow or bank transfers, most orders will never be designated transactions. The rules bite when customers pay large sums in cash in a showroom, or try to split cash payments. Check ACD's guidelines for exactly what counts as a cash equivalent.

NRIC numbers: collect only when the rules require it

It is tempting to ask every online buyer for NRIC "for security". Under the PDPA, organisations should generally not collect full NRIC numbers unless required by law or needed to verify identity to a high degree of fidelity. The PSPM duty to verify identity for designated transactions is a legal requirement, so collecting ID details for those customers is justified; collecting NRIC for an ordinary S$300 online order is not.

When you do collect ID details, store them securely with limited access, and keep them for the period the PSPM rules require. Our guide to NRIC collection rules under the PDPA explains the general rules and alternatives.

Fraud controls for high-value online orders

Jewellery and gold are prime targets for stolen-card fraud because they are small, valuable and easy to resell. A fraudulent order costs you the item, the payment reversal and a chargeback fee. Set up controls before launch, not after the first loss.

1. 1

   Turn on 3D Secure for high-value orders

   Requiring the cardholder's bank to authenticate shifts liability for most fraud chargebacks. Our 3D Secure explainer covers how it works.

2. 2

   Use your gateway's risk rules

   Stripe Radar, for example, can block, send for review or request 3D Secure based on risk score and custom rules (Stripe Radar docs). Shopify shows fraud analysis on each order.

3. 3

   Hold high-value orders for manual review

   Check that billing and delivery details make sense, the email and phone look genuine, and the order pattern is normal before shipping.

4. 4

   Ship with signature and insurance

   Require signature on delivery, avoid leaving parcels unattended, and keep proof of delivery for disputes.

5. 5

   Offer showroom collection for top-end pieces

   Paying online and collecting in person with ID matching the cardholder name removes most stolen-card risk.

If a chargeback does arrive, our Stripe dispute and chargeback guide explains the evidence to send. For store build costs, see what a Shopify store costs in Singapore.

Records and other ongoing duties

Registration is only the start. MinLaw also runs entity-based requirements, compliance reviews and semi-annual returns through its e-services. Build these into your yearly calendar.

Do it yourself or get help?

The MinLaw registration, CDD, CTR and STR processes are your responsibility, and MinLaw publishes guidelines and videos to help. A compliance adviser is worth involving if you handle large cash sales or bullion.

We build the online side with these rules in mind. Online Store Pro (S$3,490) sets up a jewellery catalogue with price controls by registration class and manual review for high-value orders; Online Payment Setup (S$290) configures 3D Secure and fraud rules on your gateway; and the PDPA Compliance Pack (S$690) covers notices and handling of ID data. This page is general information, not legal advice.