Statute Details
- Title: Terrorism (Suppression of Financing) (Exemption from Prohibition against Dealing) (No. 4) Order 2010
- Act Code: TSFA2002-S372-2010
- Legislation Type: Subsidiary legislation (Order)
- Authorising Act: Terrorism (Suppression of Financing) Act (Cap. 325)
- Enacting Authority: Minister for Home Affairs
- Enacting Formula Power: Powers under section 7(1) of the Terrorism (Suppression of Financing) Act
- Commencement: 9 July 2010
- Order Number: No. 4
- Singapore Legislation Reference: S 372/2010 (SL 372/2010)
- Status: Current version as at 27 Mar 2026
What Is This Legislation About?
The Terrorism (Suppression of Financing) (Exemption from Prohibition against Dealing) (No. 4) Order 2010 (“the Order”) is a targeted, person-specific exemption instrument made under Singapore’s Terrorism (Suppression of Financing) Act (Cap. 325). In plain terms, it allows certain individuals to carry out a particular transaction or arrangement that would otherwise be prohibited under section 6 of the Act.
Under the Terrorism (Suppression of Financing) legislative framework, the law imposes restrictions on “dealing” with property or other assets connected to terrorism financing concerns. Section 6 of the Act generally prohibits dealing with property that is subject to restrictions. However, Parliament has also provided a mechanism for the Minister to grant exemptions in appropriate cases. This Order is one such exemption.
Importantly, the Order does not repeal or broadly amend the Terrorism (Suppression of Financing) Act. Instead, it creates a narrow carve-out: it exempts named individuals from the application of section 6 of the Act in relation to a specific inclusion of a co-owner in a particular leasehold interest in a specified residential flat. The legal effect is therefore limited in scope, time, and subject matter.
What Are the Key Provisions?
1. Citation and commencement (Section 1)
Section 1 provides the formal citation and the date the Order comes into operation. The Order may be cited as the “Terrorism (Suppression of Financing) (Exemption from Prohibition against Dealing) (No. 4) Order 2010” and it “shall come into operation on 9th July 2010.” This matters for practitioners because any compliance assessment (for example, whether a prohibited dealing occurred before or after the exemption took effect) will depend on the commencement date.
2. The exemption (Section 2)
The core operative provision is section 2. It identifies two individuals—Husin Bin Abdul Aziz (NRIC No. S0209996I) and Rumini Binte Hassan Basri (NRIC No. S0126608Z)—and states that they are “hereby exempted from the application of section 6 of the Act” in a particular context.
The context is “in respect of the inclusion of Haryanti Binte Husin (NRIC No. S7705653Z) as a co-owner in the leasehold interest” in a specified flat: Apartment Block 334, Ubi Avenue 1, #02-809, Singapore 400334.
In practical terms, the exemption authorises (or at least removes the legal prohibition) for the relevant dealing that would otherwise be caught by section 6—namely, the legal act of adding a named person as a co-owner in the leasehold interest of the property described. This is a common type of transaction in property and family arrangements (for example, estate planning, family transfers, or restructuring of ownership), but it can be legally sensitive where terrorism-financing restrictions apply to one or more persons involved.
3. The specificity of the exemption
Although the Order is made under a terrorism-financing statute, it is drafted with a high degree of precision. It does not provide a general licence to deal with any property. Instead, it is limited to:
- the named exempted persons (Husin Bin Abdul Aziz and Rumini Binte Hassan Basri);
- the named person to be included as co-owner (Haryanti Binte Husin);
- the specific property (the flat at the stated address and unit number); and
- the specific dealing (inclusion of co-ownership in the leasehold interest).
This drafting approach is significant for compliance. It means that any dealing outside the described parameters would not be covered by the exemption and could remain prohibited under section 6.
4. Making and signature
The Order is “Made this 8th day of July 2010” and is signed by Benny Lim, Permanent Secretary, Ministry of Home Affairs. The signature and date provide evidence of the instrument’s formal validity and the administrative process by which the exemption was granted.
How Is This Legislation Structured?
This Order is extremely short and consists of a minimal structure typical of subsidiary exemption orders. It contains:
- Section 1: Citation and commencement (when the Order takes effect).
- Section 2: Exemption (the substantive operative provision).
There are no additional Parts, schedules, definitions, or procedural provisions in the extract provided. The legal work is therefore done entirely by the identification of the exempted persons and the precise description of the property and dealing that is permitted.
Who Does This Legislation Apply To?
The Order applies to the two individuals explicitly named in section 2: Husin Bin Abdul Aziz and Rumini Binte Hassan Basri. It exempts them from the application of section 6 of the Terrorism (Suppression of Financing) Act, but only for the specified purpose.
It also necessarily relates to the third named individual, Haryanti Binte Husin, because the exemption is “in respect of” her inclusion as co-owner. However, the exemption is not drafted as a general exemption for her; rather, it is framed as an exemption for the two exempted persons from the prohibition against dealing, to allow the co-ownership inclusion transaction described.
For practitioners, the key point is that applicability is transaction-specific and person-specific. If a different person were to be added as co-owner, or if the property were different, or if the dealing were structured differently (for example, through a transfer rather than an inclusion of co-ownership), the exemption would likely not apply.
Why Is This Legislation Important?
Even though this Order is narrow, it is legally important because it demonstrates how Singapore’s terrorism-financing regime balances strict prohibitions with controlled flexibility. The Terrorism (Suppression of Financing) Act aims to prevent the financing of terrorism by restricting dealings with relevant property. Yet, real-world property and family arrangements can require adjustments to ownership. Exemption orders provide a lawful pathway to permit specific transactions while maintaining the integrity of the broader regulatory framework.
From an enforcement and compliance perspective, the Order reduces legal uncertainty for the named individuals and their advisers. Without an exemption, the act of adding a co-owner could trigger liability or at least create a compliance risk under section 6. By issuing an exemption, the Minister for Home Affairs effectively confirms that—on the facts considered—this particular dealing should not be treated as prohibited.
For lawyers, the practical impact is significant in property documentation and conveyancing steps. The exemption would be relevant when preparing instruments or filings that reflect the change in co-ownership status in the leasehold interest of the specified flat. Practitioners should ensure that the transaction is executed strictly within the terms of the exemption and that the documentation aligns with the description in section 2 (including the exact address and unit, and the identity of the co-owner to be included).
Finally, this Order is a reminder that terrorism-financing restrictions can intersect with ordinary civil transactions. It underscores the need for careful screening of parties and proposed dealings, and for seeking targeted exemptions where necessary rather than assuming that routine property steps are automatically permissible.
Related Legislation
- Terrorism (Suppression of Financing) Act (Cap. 325) — in particular, section 6 (prohibition against dealing) and section 7(1) (power to grant exemptions)
Source Documents
This article provides an overview of the Terrorism (Suppression of Financing) (Exemption from Prohibition against Dealing) (No. 4) Order 2010 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.