On 4 April 2025, Singapore Customs and the Ministry of Trade and Industry issued a joint advisory on Singapore’s export controls relating to advanced semiconductor and artificial intelligence (AI) technologies (the Advisory).
The Advisory emphasised that businesses operating in Singapore must act transparently and fully comply with applicable laws and regulations on export controls. Such compliance is expected to extend beyond Singapore’s own export controls, with an express warning from the Singapore authorities that they will not condone the deliberate circumvention or violation of other countries’ export controls by Singapore intermediaries or any international business using its association with Singapore.
The Advisory noted that, in recent years, export controls had been unilaterally imposed by other countries on advanced semiconductors, semiconductor manufacturing equipment and AI-related technologies. By way of example, the Bureau of Industry and Security, which is the primary agency under the U.S. Department of Commerce charged with overseeing national security and high-technology issues, has issued export control regulations relating to semiconductors and semiconductor manufacturing equipment, as well as their derivative products.
The Advisory was issued following recent enforcement actions by the Singapore authorities (for further details, see below).
Ramping-up of export controls enforcement by Singapore authorities
Singapore’s export control regime is primarily governed by the Strategic Goods (Control) Act 2022 (SGCA) and the Regulation of Imports and Exports Regulations. The SGCA regulates the transfer of strategic goods and technologies, such as dual-use goods that are capable of military application. Goods and technologies that meet the technical specifications described in the Strategic Goods (Control) Order (SGCO) are subject to controls under the SGCA. Singapore’s export controls are aligned with major multilateral export control regimes and the sanctions imposed by the United Nations Security Council. A contravention of the SGCA may constitute an offence and can result in corporate and individual liability, with the imposition of fines and/or imprisonment. Increased penalties are prescribed for subsequent convictions. The primary enforcement agencies responsible for administering Singapore’s export controls are Singapore Customs (the government’s enforcement agency for customs and trade measures) and the Singapore Police Force.
Although Singapore’s export control regime does not oblige the relevant Singapore authorities to enforce the unilateral export controls of other countries, the Advisory makes clear that the authorities will not allow individuals or businesses operating in Singapore to use Singapore as a conduit for illicit trade activities in the areas of advanced semiconductor and AI technologies.
Recent enforcement actions confirm Singapore’s readiness to investigate companies and arrest individuals in Singapore that are suspected of engaging in fraudulent or dishonest practices to evade the export controls to which they are subject.
In February 2025 (a few weeks before the Advisory was issued), it was reported that three individuals were charged with fraud under Singapore’s criminal laws for allegedly facilitating the movement through Singapore of computer servers which were suspected of containing highly advanced chips from a well-known U.S. technology company. It was alleged that the individuals used Singapore-based entities to make false representations to two suppliers of these servers in order to mask the servers’ actual final destination. The total amount linked to these cases was reportedly in the region of S$500 million (~US$390 million). If convicted, the individuals could face imprisonment and/or fines for each fraud charge.
It was reported that the Singapore Police Force and Singapore Customs had conducted a joint operation in February 2025, raiding 22 locations in Singapore, seizing a substantial number of electronic devices and documentary records, and arresting nine individuals (including the three individuals who were charged). Since then, the authorities have also requested bank statements from various financial institutions to trace the movement of funds linked to the implicated individuals. Singapore Customs has indicated that it will continue to investigate this matter for possible violations of Singapore’s import and export control regulations.
Following the Advisory and the government probe discussed above, Singapore Customs updated its circular on 8 April 2025 to require that entities and declaring agents making declarations for the import and export of goods must state the final destination country of the goods, rather than making a declaration based on the consignee address in the commercial invoice.
In 2023, a Singapore entity was fined more than S$1.1 million (~US$0.8 million) for two counts of exporting strategic goods without the requisite export permits, in contravention of the SGCA. A sales manager and a director in charge of the entity’s import and export operations were also fined S$35,000 (~US$26,000) and S$45,000 (~US$34,000) respectively for their involvement. The entity had falsely declared to the Norwegian authorities that a multibeam echosounder system, which consisted of sub-systems listed as controlled goods under the SGCO, was for export to Indonesia. However, the true end-user was a Myanmar entity that had been rejected twice previously by the Norwegian authorities. The sales manager had fraudulently listed an Indonesian entity as the end-user to deceive the Norwegian authorities into approving the export to Singapore.
Conclusion
The Advisory, related regulatory updates and recent enforcement actions demonstrate the Singapore authorities’ readiness to safeguard the integrity of Singapore’s status and reputation as a key node in global supply chains and as a global trading hub.
Multinational companies with Singapore operations and businesses with supply chains that run through Singapore should therefore be on heightened alert in the current regulatory and trade climate, particularly in the semiconductor industry or where sensitive AI-related technologies are involved. They will need to carefully navigate the regulatory landscape to avoid being implicated in, or inadvertently facilitating transactions that could run afoul of, overlapping domestic and international export control regimes. In this regard, the Advisory encourages businesses to be proactive in taking steps to mitigate the risk of inadvertent violations of applicable export controls (including those of other countries). These steps include implementing robust internal compliance programmes, such as know-your-customer practices, end-user screenings, and risk-based screening procedures that focus on potential red flags (e.g., abnormal shipping routes).
Reed Smith has extensive experience advising on and conducting investigations in relation to export control-related matters, including in the Asia-Pacific region. Reed Smith is licensed to operate as a foreign law practice in Singapore. Where advice on Singapore law is required, we will refer the matter to and work with Reed Smith’s Formal Law Alliance partner in Singapore, Resource Law LLC, where necessary.