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Addressing Money Laundering Risks: MAS Public Consultation on Family Office Safeguards

Back in March 2023, MAS issued a circular calling for stronger AML/CFT controls in the wealth management sector and on 31 July 2023 MAS has issued a Public Consultation calling for feedback on a proposed framework for Single Family Offices (“SFOs”) operating in Singapore.

At present, as SFOs do not manage third-party assets, they can either rely on existing class exemptions from licensing requirements under the Securities and Futures Act or apply to MAS for case-by-case exemptions. 

The revised framework includes a proposal to harmonise the criteria for SFOs to be exempt from licensing and introduce new notification and reporting requirements to better monitor SFOs operating in Singapore. 

To qualify for the class exemption, SFOs must meet the following criteria:

  • be incorporated in Singapore;
  • notify MAS and confirm compliance with the qualifying criteria upon commencement of operations in Singapore;
  • report annually on total assets managed after the end of each calendar year; and
  • maintain a business relationship with an MAS-regulated financial institution that will perform anti-money laundering checks on these SFOs.

Comments are open until 30 September 2023.

The views expressed herein are those of the author(s) and not necessarily the views of FTI Consulting, Inc., its management, its subsidiaries, its affiliates, or its other professionals. 

FTI Consulting, Inc., including its subsidiaries and affiliates, is a consulting firm and is not a certified public accounting firm or a law firm. 

With the strong growth of SFOs in Singapore, one key risk that MAS is focused on with respect to wealth inflows to Singapore is potential money laundering (“ML”). To be clear, the ML risks posed by SFOs are similar to those of other high-net-worth or private banking individuals or entities. MAS’ regulatory and supervisory focus is therefore on ensuring that our financial institutions (“FIs”) address ML risks that their customers, including SFOs, may bring to Singapore.

Tags

moneylaundering, wealthmanagement, familyoffices, risk & compliance