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Plain-English Guide · PSPM / AML

The 2026 AML Code of Practice, in plain English — for jewellers

By the Guild of Jewellery Professionals and Artisans · updated 2 November 2026 · 8-minute read

Jewellery workshop bench with tools and work in progress
The rules reach the bench, the counter and the back office alike

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.

ItemThe rule
Class AAll items sold below S$2,000 per piece — S$250 per outlet per year
Class BAny item S$2,000 and above — S$350 per outlet per year
RenewalAnnual, via GoBusiness, within 3 months before expiry — a lapsed registration cannot be renewed, only re-applied for
Public listACD maintains a public List of Registered Dealers — your customers can check it
2+ premisesYou 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

  1. Risk assessment & IPPC — assess your money-laundering risk and keep internal policies, procedures and controls covering CDD, screening, STRs and records.
  2. Customer due diligence — identify and verify customers for cash transactions of S$20,000 and above; enhanced checks for higher risk.
  3. Name screening — screen against sanctions and other lists.
  4. Cash transaction reports — cash transactions of S$20,000 or more are reported.
  5. Records — keep CDD and transaction records for at least 5 years.
  6. 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:

Bulk cash, split transactions. Large cash amounts, or purchases structured to stay under reporting thresholds.
Rushed, indifferent buying. High-value purchases made quickly, with little interest in the product or price.
Young buyers, large cash. Unusually young customers spending sums inconsistent with apparent means.
Identity reluctance. Refusal or evasion when identification or purpose is requested.
Remote direction. Buyer following instructions from an absent third party — phone, messenger.
Immediate-resale signals. Questions about resale value, returns or melting — value storage, not jewellery.

⚑ 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?
If the business manufactures, imports, exports, supplies or deals in precious stones, precious metals or PSPM products — including retail jewellery — it must register with the Registrar of Regulated Dealers before dealing, and renew annually. Class A (all items below S$2,000 per piece) pays S$250 per outlet per year; Class B (any item S$2,000 and above) pays S$350 per outlet per year.
When must a jeweller check a customer's identity?
Customer due diligence is triggered for cash transactions of S$20,000 and above (single or linked), on suspicion, and for higher-risk situations. Identify and verify the customer; in higher-risk cases establish beneficial ownership and purpose. Keep the records at least 5 years.
What are the red flags in the 2026 Code of Practice?
Bulk cash or split transactions structured under thresholds; rushed, indifferent high-value buying; unusually young buyers with large cash; identity reluctance; buyers directed remotely by an absent third party; immediate-resale signals (resale value, returns, melting).
Do jewellery shop staff need AML training by law?
Yes — dealers must ensure employees have adequate AML knowledge, run ongoing training programmes, and assess understanding. The compliance officer answers for it. MinLaw's free toolkit covers what to include.
Who must appoint a compliance officer?
A dealer with two or more premises must appoint a compliance officer who is a Singapore citizen or permanent resident.
What happens if a dealer breaches the Code?
Breaching the 2026 Code of Practice is an offence. Failing to file CTRs for cash transactions of S$20,000 or more, failing to file STRs, and tipping off a customer about a report are also offences.

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
© 2004–2026 Guild of Jewellery Professionals and Artisans. This guide summarises the PSPM regime and the 2 April 2026 Code of Practice in plain language; it is not legal advice. The binding texts are the Act, its Regulations and the Code — and ACD's own guidance at acd.mlaw.gov.sg.