The European Union Data Protection Directive requires member states to place restrictions on transfers of personal data to countries that cannot guarantee an adequate level of data protection. Countries that do guarantee adequate protection enjoy a smooth business environment and an enhanced ability to participate in trade. In this paper I examine the adequacy of Singapore's data protection regime, and in particular the Model Data Protection Code. I suggest various amendments to the regime to enable Singapore to meet the Directive requirements. To carry out the assessment, I use a framework developed by the Article 29 Working Party, the body that in practice carries out the official adequacy assessments for the EU.