The Monetary Authority of Singapore ("MAS") has published a consultation paper seeking feedback on a proposed regulatory framework for single family offices ("SFOs") in Singapore ("Consultation Paper"). With the increasing number of SFOs being established in Singapore as well as the corresponding inbound wealth inflows, MAS is focused on potential money laundering related risks that could arise. The proposed regulatory framework would harmonise the criteria for SFOs to be exempt from licensing under the capital markets services regime under the Securities and Futures Act. MAS proposes to introduce a structure-agnostic licensing class exemption for SFOs so that they no longer need to choose between relying on the "related corporation" licensing exemption or seek an ad-hoc exemption, depending on the structure of the SFO and assets which it manages. The proposed regulatory framework would also impose notification and period reporting requirements to allow MAS to better monitor SFOs which are operating in Singapore.
Existing SFOs which operate in reliance on the "related corporation" licensing exemption will be given a transitional period of 6 months to make the necessary notifications under the new regime (when it comes into force). SFOs which have applied for tax incentives under Sections 13O or 13U of the Income Tax Act would also need to furnish new legal opinions confirming that they qualify under the proposed class exemption criteria. The Consultation Paper can be accessed at here.
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