Sanctions against Russia: Regulations for Financial Institutions
What activities are exempt from the MAS prohibitions in relation to Russia?
Payments for basic expenses and fees for certain services, as well as "specified transactions" are not prohibited under MAS Notice SNR-N01.
"Paragraph 3" mentioned below refers to "the prohibition against dealing with, and freezing of assets of, designated banks and designated entities" in MAS Notice SNR-N01.
According to MAS (Notices)
last revised 14 March 2022
3. PAYMENTS FOR BASIC EXPENSES AND REASONABLE FEES FOR CERTAIN SERVICES
Paragraph 3 of the Financial Measures Notice shall not apply to a financial institution in relation to the processing or facilitating of any payment or transfer of funds, financial assets or economic resources, where such payment or transfer is:
(a) necessary for the payment of basic expenses of any Designated Bank or Designated Entity, including (i) insurance premiums, (ii) reasonable fees for the provision of property management services or technology-related services, (iii) remuneration, allowances or Central Provident Fund contributions of employees, (iv) tax, (v) rent or storage services, (vi) mortgage payments, (vii) utility or telecommunication charges, and (viii) expenses that are necessary for the Designated Bank’s or the Designated Entity’s (as the case may be) compliance with its regulatory requirements; or
(b) exclusively for the payment of —
(i) fees or service charges imposed for the routine holding or maintenance of frozen funds, financial assets or economic resources; or
(ii) reasonable professional fees and associated expenses for the provision of audit, tax, legal or payroll services.
4. SPECIFIED TRANSACTIONS
4.2 For the purposes of paragraph 4.1, the “specified transactions” 2 are:
(a) any transaction to facilitate a person’s withdrawal of funds, financial assets or economic resources pursuant to the termination of existing business relations between the person and the Designated Bank, for the benefit of the person, where such person is not a Designated Bank; and
(b) any transaction in relation to any funds, financial assets or economic resources which are necessary for the performance of the functions of the Embassy of the Russian Federation in Singapore.