Singapore made the U.S. Treasury’s watchlist for currency manipulation for the first time, throwing a spotlight on its exchange rate policies.

The U.S. uses three criteria to determine if a country is a currency manipulator: a current-account surplus of more than 2% of gross domestic product; a bilateral goods trade surplus with the U.S. of at least $20 billion; and intervention in the foreign-exchange market that exceeds at least 2% of GDP.

Countries that meet two of the three limits are placed on the watchlist. Being labeled a currency manipulator doesn’t come with immediate penalties and the U.S. hasn’t named any of its major trade partners a manipulator since 1994.

Unlike most central banks, the Monetary Authority of Singapore uses the exchange rate as its main policy tool, intervening in the foreign currency market to keep inflation under control. The Monetary Authority of Singapore said in a statement on Wednesday it doesn’t manipulate its currency for export advantage.

Here’s a look at how Singapore stacks up against the Treasury’s criteria:

Current Account

Singapore has one of the world’s biggest current account surpluses of more than 17% of gross domestic product, mainly due to its trade reliance. It also has a high savings rate, reflecting in part the government’s compulsory savings scheme for citizens and “relatively modest” spending on social safety nets, like healthcare and unemployment insurance, according to the Treasury.

While there are “certain structural factors” for the surplus, the Treasury said Singapore should reduce its external balances, including by allowing further appreciation in the currency.

The MAS said it expects the current account surplus will be reduced over time as rising wealth boosts consumption and once public and private savings are drawn down for the needs of an aging population.

Currency Intervention

The Treasury recognized Singapore’s use of the exchange rate as its main monetary policy tool, which necessitates frequent currency intervention to keep the rate within a target band. But it raised concerns about “persistent, one-sided intervention in the foreign exchange market.”

The MAS doesn’t disclose details of its foreign intervention, but will begin doing so next year, a move welcomed by the Treasury. Singapore added more than $17 billion to foreign reserves last year. As a proxy for currency intervention, that equates to 4.6% of GDP, more than double the Treasury’s threshold.

Bilateral Trade

Singapore had a trade deficit with the U.S. of almost $6 billion in 2018, which should keep the currency manipulator tag at bay.