Series
Publications
Series
Publications
Singapore remains a trusted financial centre and a well-regarded destination for asset and wealth management, positioning itself as a strategic gateway to Asia. Over the past five years, the compounded annual growth rate of wealth management assets under management (AUM) in Singapore came up to about 10%, driven by an increase in valuation and net inflows across traditional and alternative assets, as well as in wealth management and many other activities.[1] Based on the latest asset management survey, Singapore's AUM in 2023 increased by 10% to S$5.4 trillion (US$4.1 trillion), despite challenges such as geopolitical tensions, market uncertainties, and supply chain disruptions.[2]
Part of this growth was due to an increase in the number of single-family offices in Singapore. By the end of 2024, the number of single-family offices (SFO) in Singapore exceeded 2,000, which represented an increase of at least 42.8% from the number of SFOs in end-2023.[3] The number of licensed or registered fund management companies in Singapore also increased from 1,194 in December 2022 to 1,250 as at December 2023.
Underpinning this growth is Singapore’s pro-business and pro-innovation stance, which has given investors a stable, well-regulated environment where they can adopt a long-term view. This can be seen from the Monetary Authority of Singapore’s (MAS) grant of tax incentives to around 1,650 SFOs by the end of August 2024.[4]
As a result, global and regional asset managers continue to show interest in establishing offices in Singapore to tap into regional opportunities.[5]
Singapore's fund management regulatory landscape has also changed over the past year, as part of the MAS’ continued efforts to ensure its regulatory strategy aligns with the maturation and growth of the fund management industry. For instance, while the MAS has simplified the regulatory regime for fund managers, it also enhanced certain business conduct requirements, as part of its ongoing focus on consumer protection.
Maturing and growth of fund management industry – repeal of RFMC regime
The MAS has, on 1 August 2024, repealed the Singapore Registered Fund Management Companies (RFMC) regime. Existing RMFCs that had intended to continue with regulated fund management activities would have to become a licensed fund management company from that date onwards. In repealing the regime, the MAS was of the view that the RFMC regime had served its purpose of transitioning previously exempt fund managers, and that it was timely to simplify the regulatory regime and harmonise requirements for fund managers. A simplified regulatory regime with harmonised requirements for all fund managers would also serve to support sustainable growth of the fund management industry in the longer term.
Changes to application / notification forms
The MAS has published updated forms for various financial institutions to notify the MAS or apply to the MAS in relation to various matters. These include (1) the application form for appointment of chairperson, chief executive officer, director, or key persons, (2) the application form for potential acquirers to seek the MAS' approval for obtaining effective control of capital markets services (CMS) licensees, (3) annual declaration for arrangements with foreign related corporations and/or foreign offices notified under the exemption regulations, and (4) the integration of the usual licence application form for fund managers (Form 1A) into the broader Form 1, among others.
Framework for SFOs
The MAS has published its responses to feedback received from the public regarding its proposed framework for SFOs operating in Singapore. The MAS’ intention behind the proposed framework was to create a simplified class exemption regime for SFOs, while addressing the associated potential money laundering risks posed by SFOs. The framework aims to achieve this by harmonising the criteria for SFOs to be exempt from licensing under the Securities and Futures Act 2001 (SFA), while introducing new notification and reporting requirements to allow better monitoring of SFOs operating in Singapore. The final form of the framework is currently under the MAS’ review.
Mitigating conflicts of interests
The MAS continues to focus on the need to protect customers’ interest and enhance their confidence in the financial sector. For fund management companies, the MAS has updated the Guidelines on Licensing and Conduct of Business for Fund Management Companies (FMCs), to place greater emphasis on FMCs to mitigate actual or potential conflicts of interests.
The updated guidelines provide that FMCs should (1) take steps to prevent circumstances that could lead to actual conflicts from arising, (2) ensure that conflicts of interests are managed in the best interest of their customers, (3) have policies to mitigate conflicts of interests (which should be independently reviewed and approved by an appropriate level of authority), and (4) document assessment of conflicts and mitigating measures taken.
The MAS has also set out in the updated guidelines examples of conflicts of interests that may arise, as well as examples of good practices for mitigating such conflicts.
Fair dealing
Staying with the MAS’ focus on the need to protect customers’ interests and enhance their confidence in the financial sector, the MAS has published a revised Guidelines on Fair Dealing - Board and Senior Management Responsibilities for Delivering Fair Dealing Outcomes to Customers [FSG-G04] (Guidelines) which took effect immediately on 30 May 2024.
Notably, the Guidelines now cover all financial institutions (FIs) and products, mandate the requirement for product manufacturers to align design offerings with target client segments, and strengthen requirements on unilateral right-of-review clauses. Read more about this on our post.
AML/CFT
Anti-money laundering and countering the financing of terrorism (AML/CFT) remains a significant priority for Singapore regulators, with efforts extending beyond fund managers to encompass all sectors and financial institutions across the nation. Over the past year, there have been noteworthy advancements in AML practices both at the national level and specifically from the MAS. In the latest MAS Enforcement Report, the MAS also indicated that enforcing AML/CFT controls will continue to be a key area of enforcement focus going forward.
Consultation Paper on the Proposed Amendments to Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Notices for Financial Institutions and Variable Capital Companies (VCCs): The MAS has published a consultation paper seeking feedback on proposed amendments to AML/CFT Notices for FIs and VCCs. The consultation proposes: (i) amendments to clarify that money laundering (ML) includes proliferating financing (PF), and that the ML/terrorism financing (TF) risk assessments carried out by FIs and VCCs include PF risk assessments; and (ii) amendments to align the wording of MAS Notice TCA-N03 with the Trustees Act 1967 and contemplated legislative changes, arising from the revised standards set by the Financial Action Task Force, the global standard-setter for measures to combat ML, TF and PF. The consultation has closed on 8 May 2025.
IMC publishes recommendations to strengthen Singapore’s AML framework: The Inter-Ministerial Committee (IMC) has released its report on its findings and recommendations following a review of Singapore’s AML framework. This report focuses on proactive prevention, timely detection, and effective enforcement based on lessons learned from a significant money laundering case in August 2023.
Singapore’s National AML strategy: Singapore has published its National AML Strategy, as part of continuing efforts to maintain the effectiveness of its AML framework. The National AML Strategy focuses on prevention, detection, and enforcement measures against money laundering. This strategy is supported by societal collaboration, legal frameworks, and international cooperation to maintain an effective AML framework.
MAS provides further guidance on its AML/CFT supervisory expectations from recent inspections: The MAS recently conducted a series of AML/CFT inspections across a range of FIs and published an information paper. The information paper sets out the MAS’ supervisory expectations and recommends good practices for developing effective AML/CFT frameworks and controls, which FIs should benchmark themselves against.
Artificial Intelligence (AI) Regulatory Updates
With recent advancements in AI, this has led to an increased interest in leveraging AI, particularly in generative AI (Gen AI). FIs are harnessing AI in a wide range of use cases, including risk management, customer engagement, servicing and to support its internal operational processes. Despite the benefits AI brings to these areas, irresponsible development or deployment can heighten risk exposure. Consequently, regulators have issued guidance to financial institutions on the responsible use of AI.
Use of personal data in AI: The Personal Data Protection Committee (PDPC) has published a set of advisory guidelines (titled the PDPC Advisory Guidelines on use of Personal Data in AI Recommendation and Decision Systems) on the use of personal data in AI recommendation and decision systems. These guidelines focus on the use of personal data to make autonomous decisions or assist a human decision-maker through recommendations and predictions.
Data governance and management: The MAS published an information paper on data governance and management practices, after conducting thematic inspections on the data governance and management frameworks of selected banks, with a focus on data quality. The information paper sets out the MAS’ supervisory expectations and good practices that banks and finance companies should work towards. While the best practices apply to banks and finance companies, other types of financial institutions should also work towards achieving the best practices.
Cyber risks associated with generative artificial intelligence: The MAS published an information paper on cyber risks associated with generative artificial intelligence. The paper aims to raise financial institutions’ awareness by providing an overview of key cyber threats arising from generative AI, the risk implications, and some of the mitigation measures that financial institutions could take to address the risks.
Building a trusted AI ecosystem: The AI Verify Foundation and Infocomm Media Development Authority (IMDA) have published the Singapore Model AI Governance Framework for Gen AI to build a trusted AI ecosystem. This framework contains several recommendations which may require AI developers and companies to shoulder more responsibility around Gen AI, with goals around safety, accountability, transparency, and security.
Significant Investments Review Act 2024
On 28 March 2024, the Significant Investments Review Act (SIRA) came into force. SIRA sets out a new investment management regime to regulate significant investments in certain entities that are designated as critical to Singapore’s national security interests.
Consultation Paper on Providing Retail Access to Private Market Investment Funds: The MAS published a consultation paper seeking feedback on a regulatory framework for long-term investment funds (LIF), which is intended to provide retail investors access to private market investments. Under the proposed framework, a LIF can take the form of two possible structures:
The MAS is seeking feedback on (i) the appropriate regulatory requirements for each of these two possible structures (e.g., requirements relating to the manager) and (ii) the type of private market investment assets that can be suitably offered to retail investors under this framework (e.g., private credit, private equity). This consultation closes on 26 May 2025. Read more on about this on our post.
Expiration of the Extended Variable Capital Companies Grant Scheme (VCCGS): The extended VCCGS has ended, as of 15 January 2025 (with any final applications having to be submitted by 15 April 2025 for the MAS’ consideration). This scheme was originally introduced on 15 January 2020 to bolster the adoption of Variable Capital Companies (VCC) in Singapore by offering qualifying Singapore-based fund managers a co-funding grant and its validity period had been extended from 16 January 2023 to 15 January 2025. Under the extended VCCGS, 30% of the qualifying expenses of a VCC (up to S$30,000) would be covered by the co-funding grant.
Updates to the fund tax incentive schemes under the Income Tax Act 1947: The Income Tax (Amendment) Act 2024 is effective as of 1 January 2025, following the issue of Circular FDD Cir 10/2024 by the MAS on 1 October 2024 which sets out certain details of the extension and revisions made to the fund tax incentive schemes. With these changes, the MAS considered the diverse use cases within Singapore's asset and wealth management industry and sought to balance the appeal, practicality and relevance of the tax incentive schemes while introducing certain changes anchored around economic substance from a policy perspective.
Streamlining and expanding regulatory powers – Financial Services and Markets Act 2022: The Financial Services and Markets Act 2022 (FSMA), an omnibus act governing the regulation of financial services and markets, has partially come into force. The FSMA is being implemented in phases. Phase 2A, which commenced in May 2024, introduced new provisions on technology and risk management which gives the MAS greater power to issue directions or regulation for the management of technology risk. Phase 2B, which commenced on 31 July 2024, introduced and implemented the MAS’ harmonised and expanded power to issue prohibition orders. The MAS also launched Collaborative Sharing of Money Laundering/Terrorism Financing Information & Cases (COSMIC), which is the first centralised digital platform to facilitate sharing of customer information among financial institutions to combat money laundering, terrorism financing and proliferation financing globally. The first batch of participants are limited to certain prescribed banks, although the MAS aims to progressively expand COSMIC to a wider segment of the financial sector in subsequent phases, as appropriate.
Harmonising MAS’ investigative and supervisory powers: The Financial Institutions (Miscellaneous Amendments) Act 2024 (FIMA) came into force partially on 30 August 2024 and 24 January 2025. FIMA introduces amendments to various MAS-administered legislation, such as the SFA and the Financial Advisers Act 2001 (FAA). The changes enhance the MAS’ oversight and regulatory powers, as well as facilitate greater inter-agency collaboration. Read more about this on our post.
Changes to the statutory change in control approval requirements for CMS licensees: The change in control requirements under the SFA, in respect of CMS licensees (which include licensed fund managers), have been amended such that:
These changes are reflected in the amendments to section 97A of the SFA, effective from 24 January 2025.
The MAS continues to focus on market abuse, financial services misconduct and money laundering-related control breaches. In 2024, the MAS brought a couple of cases against fund management companies and their directors / senior management for breaches of laws and regulations. Looking ahead to 2025/2026, the MAS will also look towards bolstering its enforcement capabilities to address risks in the digital asset ecosystem, by working closely with overseas regulators and industry stakeholders.
Market abuse
Former director of a licensed fund management company (LFMC) convicted and imprisoned for engaging in acts likely to defraud investors: In July 2024, Mr Sun Weiyeh, a former fund manager, was sentenced to six months' imprisonment for defrauding investors by selling two OTC bonds at lower prices from one fund to another for his benefit, resulting in a US$342,500 loss to investors of a fund managed by his company. This was the first conviction under the SFA for fraudulent or deceptive conduct relating to OTC bond trading, which followed a joint investigation by the MAS and the Singapore Police Force.
Financial services misconduct
MAS takes enforcement action against RFMC and its executive director and CEO: In July 2024, the MAS took enforcement action against China Capital Impetus Asset Management Pte. Ltd. (CCAIM), its executive director and former CEO for breaches of the Securities and Futures (Licensing and Conduct of Business) Regulations (SF (LCB)R). CCAIM had failed to:
The MAS also declined CCAIM’s application to upgrade to an LFMC, which means that it can no longer undertake fund management activity in Singapore following the repeal of the RFMC regime. The MAS also issued a 2-year prohibition order to the former CEO and executive director for failing to take reasonable steps to secure compliance with the SF(LCB)R.
Separately, the MAS had also in 2024 reprimanded another RMFC and its executive director / CEO for breaches of the SF(LCB)R.
Money laundering-related control breaches
MAS imposed composition penalties on two fund management companies for failures in complying with AML/CFT requirements: Atrium Asia Investment Management Pte. Ltd. (AAIM) and Swiss-Asia Financial Services (SAFS) were found to have breached AML/CFT requirements on multiple occasions, including having inadequate internal policies and procedures, risk assessment and customer due diligence. The MAS imposed a S$1.9 million penalty on AAIM, and imposed a S$2.5 million penalty on SAFS. The CEO of the firms (and COO of one of the firms) were also reprimanded for failing to ensure compliance.
Potential upcoming enforcement focus – use of social media
One potential upcoming area of enforcement focus could be the use of social media for public disclosures of sensitive information relating to companies. While there are yet to be enforcement actions taken in Singapore on such matters, foreign cases act as a reminder to clients that ensuring strict compliance with disclosure standards helps protect market fairness and corporate reputation.
DraftKings Settles Regulation FD Violation Charges (USA): In 2023, DraftKings faced charges for violating the Regulation Fair Disclosure (FD) rules as its CEO prematurely disclosed performance information for the second quarter on his personal X and LinkedIn accounts, ahead of the company’s official announcement. To settle these charges, DraftKings agreed to pay a US$200,000 penalty.
Information Leak via WeChat: In 2018, another incident in China occurred when a board secretary accidentally leaked sensitive information about an asset restructuring through a WeChat message sent to the wrong group. A warning was issued to this person.
Clamping down on rolling bad apples
The practice of conducting reference checks is not new in Singapore. However, noting that there are differing standards among FIs’, the MAS plans to introduce mandatory reference check requirements for all FIs.
Under the new requirements, FIs will be required to perform mandatory reference checks on certain senior managers and material risk personnel as part of the hiring process. FIs must also respond to reference check requests, based on a set of minimum mandatory information, within a specified period of time. These requirements will be imposed by Notice(s), and the MAS will be consulting on the draft Notices in due course. Read more about this on our post.
Amendments to the Limited Partnerships Act
With the objective of ensuring that the regulatory framework governing Singapore limited partnerships remains relevant and to reinforce Singapore’s position as a leading fund management hub, the Accounting and Corporate Regulatory Authority (ACRA) had proposed a suite of changes to the Limited Partnerships Act and sought to obtain public feedback on the proposed changes. The public consultation exercise ran from 4 October 2021 to 1 November 2021 and the final proposed amendments to the Limited Partnerships Act are currently still under review by ACRA.
Regulating asset tokenisation in the funds space
Project Guardian is an ongoing collaborative initiative between the MAS and other FIs, industry associations and international policymakers, to enhance the liquidity and efficiency of financial markets through asset tokenisation. To deliver real and widescale benefit in the tokenisation space for fund managers, Project Guardian established an Asset and Wealth Management industry group, which brought together the combined working knowledge and experience of members across the fund industry. In November 2024, the group published a join report introducing the Guardian Funds Framework. This framework sets out an initial set of non-prescriptive standards and industry best practices for tokenised funds, to enable the adoption of asset tokenisation in the funds space.
[1] "Building a Stronger Tomorrow: Family Offices in our Flourishing Wealth Management Landscape" - Speech by Mr Chee Hong Tat, Minister for Transport and Second Minister for Finance, and Deputy Chairman of the Monetary Authority of Singapore, at the Global-Asia Family Office Summit on 16 September 2024.
[2] The Monetary Authority of Singapore’s Singapore Asset Management Survey 2023.
[3] The Straits Times, 15 January 2025, “S’pore must continue to attract investors to build regional HQs, grow wealth here: Chee Hong Tat”.
[4] The Business Times, 14 January 2025, “Singapore family offices exceed 2,000 in 2024, up 43% on year”.
[5] Singapore Asset Management Survey 2023, supra n 2.
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