In July 2023, the Monetary Authority of Singapore (“MAS“) published its Consultation Paper on Proposed Framework for Single Family Offices (“Consultation“). The Consultation proposed to (i) harmonise the criteria for single family offices (“SFOs“) to be exempt from licensing under the Securities and Futures Act (SFA); and (ii) introduce new notification and reporting requirements to better monitor SFOs operating in Singapore. For more information on the Consultation, please see our August 2023 Legal Update titled “MAS Consults on Revised Licensing Exemption Framework, New Notification and Reporting Requirements for Single Family Offices“.
On 6 November 2024, MAS responded to feedback received from the Consultation, covering several changes and clarifications to the proposed framework in relation to:
- Qualifying criteria for exemption, such as types of ownership structures and entities for which SFOs can manage monies;
- Maintaining business relations with MAS-regulated financial institutions (“FIs”): the scope and applicability of anti-money laundering and countering of financing of terrorism (“AML/CFT“) checks, including for an SFO’s fund vehicle (“FV“);
- Notification and annual reporting requirements, including extending the timeline for initial notification and narrowing the scope of disclosure for proceedings against family members; and
- Implementation plan, such as an extension of the transitional period from six months to one year.
In this Update, we expand on MAS’ key responses, including its revisions to the proposed licensing exemption framework.
For more information, click here to read the full Legal Update.
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