Following recent regulatory developments and in-depth technical sessions on the subject, we are issuing this update to summarise the key changes under the Corporate Service Providers Act 2024 and the evolving anti-money laundering (AML) landscape in Singapore.<\/p>\n
This note consolidates critical information for corporate services practitioners and highlights areas requiring immediate attention.<\/p>\n
Singapore\u2019s position as a global financial and trading hub exposes it to significant cross-border risks, including proceeds from foreign illicit activities. The Financial Action Task Force (FATF) is set to assess Singapore\u2019s AML regime in August 2025, with a focus on the country’s understanding and mitigation of these risks.<\/p>\n
Key money laundering (ML) threats identified include:<\/p>\n
Cyber-enabled fraud<\/strong>, with a high number of cases originating from foreign syndicates.<\/p>\n<\/li>\n Organised crime<\/strong>, particularly illegal online gambling involving layering of illicit funds across multiple jurisdictions.<\/p>\n<\/li>\n Tax crimes and corruption<\/strong> originating from abroad, leveraging Singapore\u2019s reputation as a wealth management hub.<\/p>\n<\/li>\n Trade-based money laundering<\/strong>, an inherent threat given Singapore’s role as a trading and transportation hub.<\/p>\n<\/li>\n<\/ul>\n The CSP Act and its subsidiary legislation came into effect on 9 June 2025, with a six-month transition period for new entrants ending on 9 December 2025. A key change is the significant expansion of the scope of services that require registration with ACRA.<\/p>\n Registration is now required for any entity providing corporate services in or from Singapore<\/strong>, irrespective of whether they file transactions with ACRA. This captures activities beyond the previous Filing Agent framework.<\/p>\n Key activities triggering registration include:<\/strong><\/p>\n Designated Activities in conjunction with Accounting Services:<\/strong> An entity must register if it performs any of the following activities in relation to the provision of accounting services for the same client:<\/p>\n Buying or selling real estate.<\/p>\n<\/li>\n Managing customer money, securities, or other assets.<\/p>\n<\/li>\n Managing bank, savings, or securities accounts.<\/p>\n<\/li>\n Organising contributions for the creation, operation, or management of corporations.<\/p>\n<\/li>\n Creating, operating, or managing legal persons\/arrangements, or buying and selling business entities.<\/p>\n<\/li>\n<\/ul>\n<\/li>\n Provision of Address Services:<\/strong> Registration is also required for providing:<\/p>\n Registered Office<\/strong> (as defined under the Companies Act).<\/p>\n<\/li>\n Business Address<\/strong> at which a customer operates.<\/p>\n<\/li>\n Correspondence Address<\/strong> for written contact.<\/p>\n<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n Important Note on Landlord-Tenant Relationships:<\/strong> A landlord leasing out a dedicated physical space under a tenancy agreement is not required to register. However, providers offering a business address without a fixed physical space (e.g., virtual office providers) are within scope and must register. The nature of the arrangement must be clearly documented in the contract.<\/p>\n Registered CSPs are required to perform CDD measures before providing any corporate service. This includes:<\/p>\n Identifying and verifying the customer and their beneficial owner(s).<\/p>\n<\/li>\n Obtaining information on the purpose and intended nature of the business relationship.<\/p>\n<\/li>\n Screening against relevant sanctions and watchlists.<\/p>\n<\/li>\n<\/ul>\n Good Practices and Common Weaknesses:<\/strong><\/p>\n Good Practices:<\/strong> Screening against commercial databases, verifying government-issued IDs, and retaining copies.<\/p>\n<\/li>\n Common Weaknesses:<\/strong> Inadequate risk assessments, neglecting to identify beneficial owners, failing to verify customer particulars, and non-retention of CDD records for the mandatory five years.<\/p>\n<\/li>\n<\/ul>\n If CDD cannot be completed, the CSP must decline to provide the service, terminate the relationship, document the reasons, and consider filing a Suspicious Transaction Report (STR).<\/p>\n To mitigate the risks of non-face-to-face transactions, the Act mandates specific measures:<\/p>\n Incorporations and Sale of Shelf Companies:<\/strong> A live video call is required with at least one proposed director (excluding a nominee director) or a member holding at least 50% of the voting rights.<\/p>\n<\/li>\n This requirement cannot be substituted by third-party verification platforms or notarised documents.<\/strong><\/p>\n<\/li>\n Director Appointments:<\/strong> When appointing a director who is not physically present, the CSP must ensure Form 45 is signed by the proposed director and retain a copy. The CSP cannot sign on behalf of the director.<\/p>\n<\/li>\n<\/ul>\n A person cannot act as a nominee director “by way of business” unless their appointment is arranged by a registered CSP. The registered CSP is now responsible for conducting a “fit and proper” assessment<\/strong> of these nominees.<\/p>\n The assessment considers factors such as:<\/p>\n Past convictions for fraud, dishonesty, or relevant offences.<\/p>\n<\/li>\n Previous conduct and compliance history, including any disqualifications or composition fines.<\/p>\n<\/li>\n Competency, capacity, and capability, including the number of existing directorships. Individuals with over 50 directorships warrant a closer assessment of capacity.<\/p>\n<\/li>\n<\/ul>\n STRs are filed with the Suspicious Transaction Reporting Office (STRO) via the SONAR<\/strong> platform. Key deadlines include:<\/p>\n STRs must be filed within five business days<\/strong> upon establishing suspicion.<\/p>\n<\/li>\n For higher-risk cases (e.g., terrorism financing, sanctions), reports must be filed within one business day<\/strong>, if not immediately.<\/p>\n<\/li>\n<\/ul>\n Maintaining an active SONAR account is a critical compliance requirement.<\/p>\n The wealth management sector is an area of increased regulatory focus due to its inherent risks. For higher-risk customers (including those in the Global Investor Programme and Single Family Offices), enhanced CDD is required. This includes establishing both the Source of Wealth (SOW)<\/strong> and the Source of Funds (SOF)<\/strong> for the customer and their beneficial owners. These checks apply regardless of the customer\u2019s participation in tax incentive schemes or investment programmes.<\/p>\n We recommend that accounting firms undertake a review of their compliance frameworks against the new requirements, paying particular attention to:<\/p>\n Scope of Registration:<\/strong> Assessing if all business entities within the group that provide relevant services are properly registered.<\/p>\n<\/li>\n Fit and Proper Assessments:<\/strong> Establishing a robust framework for assessing nominee directors.<\/p>\n<\/li>\n STR Preparedness:<\/strong> Ensuring that staff are trained to identify suspicious activity and that SONAR accounts are active and accessible for timely reporting.<\/p>\n<\/li>\n<\/ol>\n This technical update serves as a guide for practitioners to align their practices with the current regulatory expectations under the new CSP Act.<\/p>\n Disclaimer:<\/strong> This technical note is for general guidance and informational purposes only and does not constitute professional advice. It is based on materials from a training session and should not be relied upon as a substitute for specific legal or compliance advice.<\/p>\n","protected":false},"excerpt":{"rendered":" Following recent regulatory developments and in-depth technical sessions on the subject, we are issuing this update to summarise the key changes under the Corporate Service Providers Act 2024 and the evolving anti-money laundering (AML) landscape in Singapore. This note consolidates critical information for corporate services practitioners and highlights areas requiring immediate attention. 1. Singapore’s Evolving […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"nf_dc_page":"","_et_pb_use_builder":"","_et_pb_old_content":"","_et_gb_content_width":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[7,13,12,8,6],"tags":[],"class_list":["post-2774","post","type-post","status-publish","format-standard","hentry","category-accounting","category-auditing","category-company-law","category-incometax","category-techupdates"],"jetpack_featured_media_url":"","jetpack_sharing_enabled":true,"_links":{"self":[{"href":"http:\/\/ehluar.com\/main\/wp-json\/wp\/v2\/posts\/2774","targetHints":{"allow":["GET"]}}],"collection":[{"href":"http:\/\/ehluar.com\/main\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"http:\/\/ehluar.com\/main\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"http:\/\/ehluar.com\/main\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"http:\/\/ehluar.com\/main\/wp-json\/wp\/v2\/comments?post=2774"}],"version-history":[{"count":1,"href":"http:\/\/ehluar.com\/main\/wp-json\/wp\/v2\/posts\/2774\/revisions"}],"predecessor-version":[{"id":2775,"href":"http:\/\/ehluar.com\/main\/wp-json\/wp\/v2\/posts\/2774\/revisions\/2775"}],"wp:attachment":[{"href":"http:\/\/ehluar.com\/main\/wp-json\/wp\/v2\/media?parent=2774"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"http:\/\/ehluar.com\/main\/wp-json\/wp\/v2\/categories?post=2774"},{"taxonomy":"post_tag","embeddable":true,"href":"http:\/\/ehluar.com\/main\/wp-json\/wp\/v2\/tags?post=2774"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}2. The Corporate Service Providers Act: Scope and Registration<\/h4>\n
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3. Enhanced Customer Due Diligence (CDD) Obligations<\/h4>\n
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4. Non-Face-to-Face Measures: Live Video Calls<\/h4>\n
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5. New Requirements for Nominee Directors<\/h4>\n
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6. Suspicious Transaction Reports (STRs)<\/h4>\n
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7. Focus on the Wealth Management Sector<\/h4>\n
8. Key Takeaways<\/h4>\n
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