SINGAPORE - 2008 NATIONAL TRADE ESTIMATE REPORT

UNCLAS SECTION 01 OF 08 SINGAPORE 002016 SIPDIS STATE FOR EB/TPP/BTA USDOC FOR JBAKER STATE PASS USTR FOR AUSTR WEISEL, DBELL AND GBLUE SENSITIVE BUT UNCLASSIFIED SIPDIS E.O. 12958: N/A TAGS: ECON ETRD EINV EFIN KIPR ECPS SN SUBJECT: SINGAPORE - 2008 NATIONAL TRADE ESTIMATE REPORT REF: STATE 119765 ¶1. (U) In response to reftel instructions, this message is Post's draft chapter on Singapore for the 2008 National Trade Estimate Report. We assume that Washington agencies will update the trade and investment data in the first three paragraphs of the report as they have done in the past. Per reftel instructions, we have emailed to USTR the text of the draft report in MS Word format and showing changes from last year's version. ¶2. (SBU) Begin text of the 2008 National Trade Estimate report: TRADE SUMMARY -------------- The U.S. goods trade surplus with Singapore was $6.9 billion in 2006, an increase of $1.4 billion from $5.5 billion in 2005. U.S. goods exports in 2006 were $24.7 billion, up 19.6 percent from the previous year. Corresponding U.S. imports from Singapore were $17.8 billion, up 17.7 percent. Singapore is currently the 9th largest export market for U.S. goods. U.S. exports of private commercial services (i.e., excluding military and government) to Singapore were $5.8 billion in 2005 (latest data available),and U.S. imports were $3.7 billion. Sales of services in Singapore by majority U.S.-owned affiliates were $6.2 billion in 2004 (latest data available),while sales of services in the United States by majority Singapore-owned firms were $1.6 billion. The stock of U.S. foreign direct investment (FDI) in Singapore in 2005 was $48.1 billion (latest data available),down from $57.1 billion in 2004. U.S. FDI in Singapore is concentrated largely in the manufacturing, wholesale trade, information, and professional scientific and technical services sectors. FREE TRADE AGREEMENT (FTA) -------------- The United States and Singapore signed a Free Trade Agreement (FTA) on May 6, 2003, which entered into force on January 1, 2004. It was the first comprehensive FTA the United States concluded with an Asian country, eliminating most tariffs immediately upon entry into force of the FTA and making important advances in many key areas. Among other benefits, the FTA provides strong discipline in the most competitive U.S. service sectors, enhances protection for intellectual property, makes specific commitments regarding the conduct of Singapore's government-linked enterprises and provides strong and transparent discipline in government procurement. The FTA also includes commitments to prevent illegal transshipments of all traded goods and to prevent circumvention for textiles and apparel as well as requirements to effectively enforce domestic labor and environmental laws. Since the FTA was implemented, exports from the United States have increased 49 percent through 2006, with steady growth in medical devices, machinery and construction equipment exports, and significant growth in pharmaceutical exports. In addition to the FTA with the United States, Singapore has concluded bilateral FTAs with Australia, the European Free Trade Association, Japan, Jordan, New Zealand, South Korea, India and Panama and a quadrilateral agreement with Chile, New Zealand and Brunei. Singapore is negotiating FTAs with Bahrain, Canada, China, Egypt, Kuwait, Mexico, Pakistan, Peru, Qatar, Sri Lanka and the United Arab Emirates. Singapore is a member of the Association of Southeast Asian Nations (ASEAN),which has concluded FTAs with China and South Korea and is negotiating FTAs with Australia, New Zealand, India, and Japan. IMPORT POLICIES -------------- Tariffs -------------- Singapore imposes no tariffs on industrial goods. It eliminated the last four remaining tariffs (covering imports of beer and certain alcoholic beverages) for goods originating in the United States when the FTA came into force. For social and/or environmental reasons, Singapore levies high excise taxes, applicable to distilled spirits and wine, tobacco products, motor vehicles (all of which are imported) and gasoline. Singapore does not impose any known restrictions or duties on imports or exports of textiles and apparel. Singapore has bound 70.5 percent of its tariff lines in the World Trade Organization (WTO). Singapore is a signatory to the SINGAPORE 00002016 002 OF 008 WTO Information Technology Agreement. Import Licenses -------------- All imports require a permit, primarily for statistical tracking purposes. Special import licenses are required for certain goods, including designated strategic items, hazardous chemicals, radiation-emitting medical devices, films and videos, arms and ammunition, agricultural biotechnology products, food derived from agricultural biotechnology products, prescription drugs, over-the-counter drugs, vitamins with very high dosages of certain nutrients and cosmetics/skin care products. Beginning in April 2008, Singapore will require that all manufacturers, importers, and wholesalers of medical devices be licensed under the Health Products Act by no later than October 2009. Singapore expanded its controlled goods list, effective January 1, 2008, to include all items covered by the Australia Group, the Nuclear Suppliers Group, the Missile Technology Control Regime, and the Wassenaar Arrangement. Singapore maintains a tiered motorcycle operator licensing system based on engine displacement, which, along with a road tax based on engine size, places U.S. exports of large motorcycles at a competitive disadvantage. The sale of chewing gum is restricted in Singapore. However, as a result of the FTA, Singapore allows the importation of chewing gum with therapeutic value for sale, subject to certain requirements. STANDARDS, TESTING, LABELING AND CERTIFICATION -------------- - Under the 2002 Consumer Protection Regulations, 45 categories of electrical, electronic, and gas home appliances and accessories are listed as controlled goods and require a stamp of approval from the Singapore government's standards and certification authority (SPRING Singapore). SPRING Singapore recognizes test reports issued by accredited testing laboratories and certification bodies, including those in the United States. Labels conforming to standardized formats are required on imported foods, drugs, liquors, paints and solvents. Agriculture -------------- Singapore's food import policy is intended to guarantee a steady and sufficient supply of healthful and high-quality foods from a broad number of countries. Singapore allows meat and poultry imports solely from countries with which it has protocol agreements. Doing so preserves its rigorous food safety requirements through the integration of foreign farm accreditation, inspection and regular testing. Export health documentation endorsed by federal health institutions must accompany every shipment of imported meat and poultry. In addition, Singapore health authorities test every shipment of imported meat and poultry visually for wholesomeness and to ensure it is free from spoilage and disease. Meat and poultry product samples are regularly sent to government laboratories for evaluation to guarantee that they do not exceed the allowable microbiological specifications for raw meat and poultry products. Singapore's Agri-food and Veterinary Authority (AVA) enforces a zero tolerance policy for salmonella enteriditis and E-coli E. 0157 in raw meat products, which is not consistent with international standards and has posed some difficulties for U.S. exporters. AVA prohibits beef imports from nations in which Bovine Spongiform Encephalopathy (BSE) has been detected, including the United States. Singapore previously required six years of non-BSE detection in a country before re-establishing trade, but has now established a minimum risk rule in line with World Organization for Animal Health (OIE) guidelines. On January 17, 2006, Singapore announced the re-opening of its market to U.S. boneless beef from animals under 30 months of age. Singapore continues to ban imports of bone-in cuts of beef and beef products from the United States. Fresh produce imports are tagged to secure their traceability to farms. Fresh produce is routinely tested to guarantee that it does not exceed maximum pesticide residue limits. In September 2006, Singapore removed a requirement for a Certificate of Age/Origin (COA) for aged distilled spirits despite concerns raised by the EU, the United States and their distilled spirits industries. In many countries, the COA is a useful tool for preventing the importation of counterfeit distilled spirits. GOVERNMENT PROCUREMENT -------------- SINGAPORE 00002016 003 OF 008 Singapore is a signatory to the WTO Agreement on Government Procurement. The FTA provides increased access for U.S. firms to Singapore's central government procurement. Some U.S. and local firms have expressed concerns that government-owned and government-linked companies (GLCs) may receive preferential treatment in the government procurement process. Singapore denies that it gives any preferences to GLCs or that GLCs give preferences to other GLCs. INTELLECTUAL PROPERTY RIGHTS (IPR) PROTECTION -------------- In line with its FTA commitments and obligations under international treaties and conventions, Singapore has developed one of the strongest IPR regimes in Asia. Amendments to the Trademarks Act, the Patents Act, the Layout Designs of Integrated Circuits Act, Registered Designs Act, and a new Plant Varieties Protection Act, and a new Manufacture of Optical Discs Act came into effect in July ¶2004. The amended Copyright Act and Broadcasting Act became effective in January 2005; the Copyright Act was further amended in August 2005. Singapore has implemented Article 1 through Article 6 of the World Intellectual Property Organization (WIPO) Joint Recommendation Concerning Provisions on the Protection of Well-Known Marks of 1999. It has signed and ratified the International Convention for the Protection of New Varieties of Plants (1991); the Convention Relating to the Distribution of Program-Carrying Signals Transmitted by Satellite (1974); the WIPO Copyright Treaty (1996); and the WIPO Performances and Phonograms Treaty (1996). Singapore is a signatory to other international IPR agreements, including the Paris Convention, the Berne Convention, the Patent Cooperation Treaty, the Madrid Protocol and the Budapest Treaty. The WIPO Secretariat opened offices in Singapore in June 2005. Amendments to SIPDIS the Trademark Act, which took effect in January 2007, fulfill Singapore's obligations in WIPO's revised Treaty on the Law of Trademarks. Transshipment -------------- To implement its FTA commitments, Singapore amended Section 31 of the Import/Export Act in November 2003 to facilitate information-sharing with U.S. Customs and Border Protection and other country officials with which it has relevant trade agreements. Nonetheless, Singapore, a major transshipment and transit point for sea and air cargo, does not collect information on the contents and destinations of most transshipment and transit trade, which accounts for 80 percent of the cargo coming through the port. This lack of information makes enforcement against transshipment or transit trade in infringing products virtually impossible. In addition, goods in transit are not subject to seizure under the Copyright Act, although it may be possible if a search warrant is obtained in advance. Internet -------------- In accordance with the FTA, Singapore's amended Copyright Act provides improved protection for digital works, and outlines requirements and procedures for removing infringing material from Internet sites. Despite the amendment, the copyright industry maintains that the new law fails to impose full liability on service providers engaged in infringing activity. U.S. industry has raised concerns that Internet piracy in Singapore is on the rise as a result of the increasing availability of the country's broadband facilities. Industry groups also claim that Section 107B of the Copyright Act violates FTA obligations by permitting entities in Singapore to "simulcast" performances over the Internet without paying the proper license fees. Enforcement -------------- In line with its FTA obligations, Singapore has taken steps to improve IPR enforcement and to lower infringement rates, which are among the lowest in the Asia Pacific region. Singapore claims that its enforcement efforts have almost eliminated the production of pirated material and blatant storefront retail piracy. According to industry estimates, Singapore's piracy rate averaged 5 to 10 percent for audio and video and 39 percent for business software. Rights holders have encountered difficulties when attempting to prosecute IP cases based on tips provided by company insiders. Singapore currently does not offer specific protection to "whistleblowers." As a result, many informants refuse to provide crucial testimony in court. SINGAPORE 00002016 004 OF 008 While a number of local educational institutions (the majority government-operated) have signed agreements to comply with their legal obligations to pay royalty fees to publishers, unlawful duplication of textbooks at some commercial copy centers continues. The police have conducted multiple raids, but, according to industry representatives, the practice is lucrative enough to continue in spite of the possibility of large fines. SERVICES BARRIERS -------------- Basic Telecommunications -------------- Any foreign or domestic company can provide facilities-based (fixed line or mobile) or services-based (local, international, and callback) telecommunications services. Under the Telecoms Competition Code 2000, the former monopoly (and 62 percent government-owned) telecommunications service provider, Singapore Telecommunications (SingTel),faces competition in all market segments, including fixed-line, mobile and paging services. Its main competitors, MobileOne and StarHub, are also GLCs. Singapore has approximately 60 facilities-based and 110 services-based operators. Facilities-based operators continue to be limited in their ability to take advantage of wholesale pricing for SingTel's ("last mile") local leased circuits. IDA first mandated this regulatory change in December 2003, but SingTel has repeatedly contested this directive, typically through requests for IDA to stay decisions or through appeals to the Minister for Information, Communications and the Arts (MICA). In October 2005, IDA amended SingTel's Reference Interconnection Offer to provide for a more appropriate, open-standard technical interface, a decision upheld by MICA in May 2006 following an appeal by SingTel. Although SingTel must now offer wholesale prices for local leased circuits at reduced rates ranging from 55 percent to 82 percent, U.S. industry is still unable to avail itself of this more competitive pricing structure due to certain uneconomical technical interconnection requirements imposed by SingTel. The United States remains concerned about the lack of transparency in some aspects of Singapore's telecommunications regulatory and rule-making process. In particular, there is no obligation to make information publicly available concerning a company's request for a stay of decision or the filing of an appeal, to request public comments about such requests, or to publish a detailed explanation concerning final decisions made by IDA or MICA. Under the FTA, Singapore agreed that dominant licensees (SingTel and StarHub) must offer cost-based access to submarine cable-landing stations and allow sharing of facilities. U.S. companies continue to have problems with access to facilities used to lay lines as provided for in the FTA. Since January 2007, SingTel has been exempted from dominant licensee obligations for the residential and commercial portions of the retail international telephone services (ITS). SingTel announced in June 2006 plans to consolidate its local exchanges but failed to provide details of specific local exchanges to be closed. This has put U.S. and other carriers' expansion plans on hold. IDA issued a decision in June 2007 that increases the notification period SingTel must provide from six to 18 months. IDA has denied requests by U.S. and other companies for interconnection at a more centralized location. Audiovisual and Media Services -------------- Singapore's local free-to-air broadcasting, cable and newspaper sectors are effectively closed to foreign firms. Section 47 of the Broadcasting Act restricts foreign equity ownership of companies broadcasting to the Singapore domestic market to less than 49 percent, although the Act gives the Media Development Authority (MDA) the authority to waive this requirement. The Singapore government also limits individual equity stakes in broadcasting companies to no more than 5 percent of issued shares. MediaCorp TV is the only free-to-air television broadcaster. It is 80 percent owned by the government and 20 percent by publicly listed Singapore Press Holdings (SPH). Under MDA rules, MediaCorp TV must outsource at least 285 hours of local content production to independent television production companies per year. The incumbent subscription TV provider, StarHub Cable Vision (SCV),is a 100-percent owned subsidiary of StarHub Ltd., a publicly listed GLC. SINGAPORE 00002016 005 OF 008 SingTel entered the subscription TV market in January 2007. Free-to-air radio broadcasters are mainly government-owned, with MediaCorp Radio Singapore being the largest operator. BBC World Service is the only foreign free-to-air broadcaster in Singapore. Singapore restricts the use of satellite dishes and has not authorized direct-to-home satellite television services. MDA must license the installation and operation of broadcast-receiving equipment, including satellite dishes. Satellite broadcasters that want to operate their own uplink facility must get a special license from MDA. Satellite broadcasters lacking their own facility are restricted to using one of four available uplink facilities. The Newspaper and Printing Presses Act restricts equity ownership (local or foreign) to 5 percent per shareholder, unless the government approves a larger shareholding, and requires that all the directors of a newspaper company be Singapore citizens. Newspaper companies must issue two classes of shares, ordinary and management, with the latter available only to citizens of Singapore or to Singapore companies approved by the government. Media businesses or professionals must be licensed by MDA in order to provide services or apparatus and equipment. Printed and audio material is no longer subject to prior review, but licensees are advised to abide by MDA guidelines. MDA requires all film and video material for distribution and screening to be certified and classified. The Singapore government can deny or revoke permits without warning or without giving a reason. Distribution, importation or possession of any "offshore" or foreign newspaper must be approved by the government. Singapore significantly restricts freedom of the press, having curtailed or banned the circulation of some foreign publications. In September 2006, Singapore banned the Far Eastern Economic Review on grounds that the publisher did not comply with Section 23 of the Newspaper and Printing Presses Act, whereby the offshore publisher must appoint a person within Singapore authorized to accept service of any notice or legal process on behalf of the publisher and post a security deposit of S$200,000 ($125,000). The Singapore government has also "gazetted" foreign newspapers i.e., numerically limited their circulation. Singapore's leaders have threatened foreign publishers with defamation suits for perceived slights, which has often resulted in the foreign publishers issuing apologies and paying damages. Legal Services -------------- U.S. and other foreign law firms with offices in Singapore face certain restrictions. They cannot practice Singapore law, employ Singapore lawyers to practice Singapore law, or litigate in local courts. Since June 2004, U.S. and other foreign lawyers have been allowed to represent parties in arbitration in Singapore without the need for a Singapore attorney to be present. U.S. law firms can provide legal services with respect to Singapore law only through a Joint Law Venture (JLV) or Formal Law Alliance (FLA) with a Singapore law firm, subject to the Guidelines for Registration of Foreign Lawyers in Joint Law Ventures to Practice Singapore Law. Singapore relaxed one of these guidelines for U.S. law firms under the FTA. Since July 2007, foreign attorneys have been allowed to own equity in JLVs up to a maximum of 25 percent of total shares. As of October 2007, 16 of the 73 foreign law firms in Singapore were from the United States. Additionally, there was one U.S. JLV and one FLA. Except for law degrees from designated U.S., Australian, New Zealand and British universities, no foreign university law degrees are recognized for the purpose of admission to practice law in Singapore. Under the FTA, Singapore has recognized law degrees from Harvard University, Columbia University, New York University and the University of Michigan. To address a perceived shortage of practicing lawyers, Singapore relaxed its criteria for admission of attorneys to the Singapore Bar, effective October 2006. One of the new criteria will admit to the Bar Singapore-citizen or permanent-resident law school graduates of the above-mentioned designated universities who were ranked among the top 70 percent of their graduating class or have obtained lower-second class honors (under the British system). As of July 2007, the government allows highly skilled foreign lawyers meeting certain criteria to practice Singapore corporate, finance and banking law. Engineering and Architectural Services -------------- SINGAPORE 00002016 006 OF 008 Engineering and architecture firms can be 100 percent foreign owned. In line with FTA provisions, and also applicable to all foreign firms, Singapore has removed the requirement that the chairman and two-thirds of the firm's board of directors be composed of engineers, architects or land surveyors registered with local professional bodies. Practicing engineers and architects must register with the Professional Engineers Board and the Architects Board, respectively. Under amended legislation, local and foreign job applicants, including U.S. degree-holders, will be required to have at least four years of practical experience in engineering or architectural works and pass an examination set by the respective Board. Accounting and Tax Services -------------- The major international accounting firms all operate in Singapore. Public accountants and at least one partner of a public accounting firm must reside in Singapore. Only public accountants who are members of the Institute of Certified Public Accountants of Singapore and registered with the Public Accountants Board of Singapore may practice public accountancy in the country. The Board recognizes U.S. accountants registered with the American Institute of Certified Public Accountants. Banking and Securities -------------- Retail Banking -------------- Singapore maintains legal distinctions between offshore and domestic banking units, and the type of license held (full, wholesale or offshore). Except in retail banking, Singapore laws do not distinguish operationally between foreign and domestic banks. The government initiated a banking liberalization program in 1999 to ease restrictions on foreign banks and has supplemented this with phased-in liberalization under the FTA. These measures include removal of a 40 percent ceiling on foreign ownership of local banks and a 20 percent aggregate foreign shareholding limit on finance companies. Singapore has granted six "qualifying full bank" (QFB) and 24 full service licenses to foreign banks, including one U.S. QFB and four U.S. full service banks. Since January 2006, under the FTA, U.S. licensed full-service banks and QFBs are able to operate at an unlimited number of locations (branches or off-premises ATMs). Non-U.S. full-service foreign banks have been allowed to operate since January 2005 at up to 25 locations. These full-service banks can freely relocate existing branches and share ATMs among themselves. They also can provide electronic funds transfer, point-of-sale debit, and Central Provident Fund (Singapore's compulsory pension fund) related services. Under the FTA, Singapore lifted its ban on new licenses for full-service banks in June 2005, and for wholesale banks in January ¶2007. Locally incorporated subsidiaries of U.S. full-service banks have been able to apply for access to local ATM networks since June ¶2006. Non-locally incorporated subsidiaries of U.S. full-service banks may begin doing so in January 2008. However, holders of cards issued locally by foreign banks or financial institutions cannot access their accounts through the local ATM networks. They are also unable to access their accounts for cash withdrawals, transfers or bill payments at ATMs operated by banks other than those within their own bank or at foreign banks' shared ATM networks. U.S. industry advocates enhancements to Singapore's credit bureau system. The Minister of Finance must provide specific types of approval for acquisitions of 5 percent, 12 percent or 20 percent or more of the voting shares of a local bank. Although it has lifted the formal ceilings on foreign ownership of local banks and finance companies, the Singapore government has indicated that it will not allow a foreign takeover of its three major local financial institutions. While foreign penetration of the Singapore banking system is comparatively high, with foreign banks holding about 40 percent of non-bank deposits, the government has stated publicly that it wants local banks' share of total resident deposits to remain above 50 percent. Restricted and Offshore Banking -------------- The Monetary Authority of Singapore (MAS) has issued 25 new wholesale bank licenses since 2001 as part of its liberalization SINGAPORE 00002016 007 OF 008 program. MAS continues to upgrade certain existing offshore banks to wholesale bank status. New foreign bank entrants are also eligible to apply for wholesale banking licenses. Unless otherwise approved by MAS, wholesale banks can operate in only one location. Restrictions on Singapore Dollar Lending -------------- Non-residents can borrow local currency freely if the proceeds are used in Singapore. Non-resident financial entities may borrow local currency freely for their use in or outside Singapore if the amount does not exceed S$5 million (US$3.3 million); if it does, the amount must be swapped or converted into foreign currency upon drawdown. There are no controls on the borrowing of Singapore dollars by residents. MAS requires banks to report their monthly aggregate outstanding Singapore dollar lending to non-resident financial institutions. Securities -------------- In January 2002, Singapore removed all trading restrictions on foreign-owned stockbrokers. Aggregate investment by foreigners, however, may not exceed 70 percent of the paid-up capital of dealers that are members of the Singapore Exchange Limited. Foreign funds may be registered directly, provided the prospectus is from an entity registered as a foreign company in Singapore and the fund is approved by MAS. Distribution Services -------------- The Ministry of Trade and Industry implemented a Multi-Level Marketing and Pyramid Selling (Excluded Schemes and Arrangements) Order in January 2002 to clarify which kinds of multi-level and direct marketing/selling arrangements, whether local or foreign, are legal in Singapore. The order prohibits compensation for recruitment of participants. It prohibits any Singapore-registered company or citizen/resident from promoting any overseas pyramid selling marketed through the Internet. Insurance businesses licensed under the Insurance Act and its subsidiary legislation, master franchise schemes, and direct selling schemes that meet conditions listed in the Order are exempted from the Act. Energy -------------- Singapore implemented the Gas (Amendment) Act in June 2007 to facilitate competition and move towards a fully liberalized energy market, in part by opening access to gas pipeline infrastructure. However, at least one U.S. company has encountered difficulties in its access bid due to lengthy delays in the review of its application by the Energy Market Authority. To date, no non-incumbent operators have been able to secure access to the Singapore section of the existing Sumatra-Singapore pipeline. INVESTMENT BARRIERS -------------- Singapore has a generally open investment regime and no overarching screening process for foreign investment. Singapore places no restrictions on reinvestment or repatriation of earnings and capital. The investment chapter of the FTA provides for national and most-favored nation treatment, the right to make financial transfers freely and without delay, disciplines on performance requirements, international law standards for expropriation and compensation, and access to binding international arbitration. ELECTRONIC COMMERCE -------------- Singapore has no significant barriers hindering the development and use of electronic commerce. The FTA contains state-of-the-art provisions on electronic commerce, including national treatment and most-favored nation obligations for products delivered electronically, affirmation that services disciplines cover all services delivered electronically, and permanent duty-free status of products delivered electronically. Singapore considers the Internet to fall within the scope of its Broadcasting Act. Internet service providers must channel all Internet traffic through Internet access service providers that function as main "gateways" to the Internet. Internet service resellers, Internet content providers, individuals who put up personal web pages, software developers, providers of raw financial SINGAPORE 00002016 008 OF 008 information and news wire services do not have to register with the Singapore Broadcasting Authority. OTHER BARRIERS -------------- Competition -------------- The FTA contains specific conduct guarantees to ensure that commercial enterprises in which the Singapore government has effective influence will operate on the basis of commercial considerations and will not discriminate in their treatment of U.S. firms. In accordance with its FTA commitments, Singapore enacted the Competition Act in 2004. Phase I established the Competition Commission of Singapore in January 2005. Phase II involved the implementation of provisions on anticompetitive agreements, decisions and practices, abuse of dominance, enforcement, and the appeals process, which came into effect in 2006. Phase III provisions pertaining to mergers and acquisitions came into effect in July 2007. The government's initial decisions under the Competition Act have focused primarily on services, including exemptions for the aviation sector. The FTA includes obligations for greater transparency among government enterprises with substantial revenues or assets. Singapore has an extensive network of government-linked corporations that are active in many sectors of the economy. Some sectors, notably telecommunications, power generation/distribution, media and financial services, are subject to sector-specific regulatory bodies and competition regulations typically less rigorous than those being implemented under the Competition Act. U.S. industry has expressed concerns about the lack of adequate trade secrets protections under Singapore law that would provide specific legal protections for commercially sensitive proprietary information. Transparency -------------- In keeping with the FTA's transparency obligations, Singapore has circulated more draft laws and regulations for public comment, including those relating to the implementation of the FTA. HERBOLD