Export Controls has been saved
With heightened concerns over global safety and security, governments worldwide have increasingly introduced export controls on both tangible goods and intangible technologies that could have military applications. Principally affected are companies in the aerospace and defence, biotechnology/chemicals and information security/encryption sectors, but controls also impact all other products defined as “dual-use” and therefore will have wide ranging impact to companies operating in other sectors who move such goods around the world as part of global supply chains.
Singapore has introduced export controls on controlled goods since 2002 via the Strategic Goods (Control) Act (Cap 300), and other subsidiary legislation made there under. The Act seeks to place controls on any act of transferring or brokering any strategic goods, strategic goods technology, and any other goods capable of being used to develop, produce, operate, stockpile or acquire weapons capable of causing mass destruction.
At Deloitte, we assist companies in managing their compliance efforts with export control requirements via a step-by-step approach by first determining whether export controls apply to the product and the activity in question, followed by hands on assistance to design, implement and effect internal processes, controls and systems to ensure that requisite licences are applied for prior to any transfer or brokering of strategic goods out of Singapore.
To assist businesses in understanding whether the Strategic Goods (Control) Act, and also other export control-oriented multilateral agreements and international conventions for which Singapore is a party to, could be applicable to their products and therefore require the appropriate licence to be obtained prior to the transfer or brokering of such goods, the following steps are generally involved:
- ECCN Classification to determine whether such goods are regarded as strategic goods
- Whether there are exceptions available against the need to obtain licensing (e.g. mass market exemptions, other exemptions available based on the specific goods)
- Whether goods brought in transit in Singapore not exceeding a certain timeframe may benefit from no licence required
- If goods are controlled and a licence is required, whether a single use or bulk permit would be ideal
- Requirements to be able to apply for licensing from Singapore Customs and timeframe
- Other compliance requirements in terms of record keeping, dealings, submission of reports to Singapore Customs, etc.
- Compliance with export control requirements is taken seriously by Singapore Customs and there are significant penalties imposed on companies for non-compliance.
In the unfortunate event that strategic goods or technology may have been shipped out or transmitted outside Singapore, we also assist with reviewing the case on hand to determine whether it would be appropriate to submit a voluntary disclosure application to Singapore Customs ahead of any audit and/or investigations.
Our network of export controls specialists comprises lawyers, ex-government officials, industry experts and consultants experienced in export controls and trade compliance.
- Export controls advisory
- Permit and schemes applications
- TradeFIRST applications
- Secure Trade Partnership (STP) status applications
For queries or assistance relating to export controls and strategic items, feel free to send us an email through the Get in Touch section below or via the online form on the link at the right.