The 2026 AML Code of Practice, in plain English — for jewellers
On 2 April 2026, Singapore's Registrar of Regulated Dealers issued a binding Code of Practice aimed squarely at jewellery and watch retailers. It came after scam-related money laundering surfaced in the trade — bulk-cash purchases in the Chinatown Complex / People's Park cluster — and it changed the daily reality of every counter in the country. Breaching the Code is an offence, not a suggestion.
This guide explains the whole regime in the order a working jeweller meets it: registration, the six standing obligations, the S$20,000 rules, the 2026 red flags, and the staff-training duty that decides what happens when an inspector walks in. No legalese; every rule cited is in force under the Payment Services (Precious Metals and Precious Stones) framework administered by the Ministry of Law's AML/CFT Division (ACD).
1. Are you a "regulated dealer"? (Probably yes)
If your business manufactures, imports, exports, supplies or deals in precious stones, precious metals or PSPM products — including retail jewellery — you must register with the Registrar of Regulated Dealers before dealing, and renew annually. It is an offence to hold out as a dealer without registration.
| Item | The rule |
|---|---|
| Class A | All items sold below S$2,000 per piece — S$250 per outlet per year |
| Class B | Any item S$2,000 and above — S$350 per outlet per year |
| Renewal | Annual, via GoBusiness, within 3 months before expiry — a lapsed registration cannot be renewed, only re-applied for |
| Public list | ACD maintains a public List of Registered Dealers — your customers can check it |
| 2+ premises | You must appoint a compliance officer who is a Singapore citizen or PR |
Pawnbrokers sit under their own regime; MAS-regulated institutions are exempt but for cash-transaction reporting.
2. The six obligations — the short version
- Risk assessment & IPPC — assess your money-laundering risk and keep internal policies, procedures and controls covering CDD, screening, STRs and records.
- Customer due diligence — identify and verify customers for cash transactions of S$20,000 and above; enhanced checks for higher risk.
- Name screening — screen against sanctions and other lists.
- Cash transaction reports — cash transactions of S$20,000 or more are reported.
- Records — keep CDD and transaction records for at least 5 years.
- Suspicious transaction reports — file STRs to the Suspicious Transaction Reporting Office when anything smells wrong. Tipping off the customer is itself an offence.
3. The 2026 Code — the scam-money wave at your counter
The Code's red flags are now every counter's daily reality. If a sale matches one, the obligation is to slow down, escalate, and where required — file:
⚑ Free for every counter in Singapore
The Guild's Red-Flag Counter Card — a printable A5 card with the red flags above and exact escalation scripts. Print one per till.
4. The staff-training duty — the part inspectors actually check
The regime does not stop at paperwork: dealers must ensure employees have adequate AML knowledge, run ongoing training programmes, and assess understanding — and the compliance officer answers for it. MinLaw's free Compliance Toolkit and e-learning tell you what to cover.
What has been missing is a jewellery-branded, counter-level, certifiable pathway for the people — which is exactly what the Guild builds. Every module of the GJPA AML Passport is mapped line-by-line to the ACD Compliance Toolkit, the Regulated Dealer's Guide and the 2026 Code of Practice; completion is registered and verifiable on the public register.
5. Around AML: the rest of the wardrobe
Compliance does not end with money-laundering. Under fair trading, the CaseTrust Jewellery Eight Fair Trade Guidelines require accurate karat and hallmark claims, lab-grown and treatment disclosure, and honest pricing — firm accreditation belongs to CaseTrust; the Guild certifies the people who must deliver it at the counter. Personal-data duties (PDPA) and do-not-call rules apply to every customer list a jeweller keeps. The Guild's free PDPA Jeweller's Checklist covers those five obligations as a one-page tick-list.
Frequently asked questions
Does a jewellery shop in Singapore need to register as a regulated dealer?
When must a jeweller check a customer's identity?
What are the red flags in the 2026 Code of Practice?
Do jewellery shop staff need AML training by law?
Who must appoint a compliance officer?
What happens if a dealer breaches the Code?
Where to go next
The Guild's AML & Compliance Hub holds the full regime in plain English, the training ladder (AML-Aware, AML-Practitioner, AML-Compliance Officer), and every free template: the IPPC policy skeleton, the CDD form template and the counter card. Training delivery for cohorts is available through the Guild's education partner, JDMIS.
Open the Compliance Hub Get the free counter card