In brief
On 6 November 2024, the Monetary Authority of Singapore (MAS) published its responses to the feedback on the July 2023 consultation paper that set out a proposed regulatory framework for Single Family Offices (SFOs) operating in Singapore. SFOs are exempt from licensing under the Securities and Futures Act 2001 (SFA), and the proposals are aimed at harmonizing the criteria for a simplified class exemption regime and addressing potential money laundering (ML) risks posed by SFOs.
Our earlier alert on the consultation can be accessed here.
MAS will provide further details on the effective date of implementation, revised legislation and mode of submission for the initial notification and annual return prior to the implementation of the SFO framework.
Key proposed measures under the framework
MAS has provided further details and clarifications to the key measures that will be implemented under the SFO framework. These further details and clarifications are in red font below:
Implementation plan
MAS proposes a transitional period of one year from the effective date of the proposed SFO framework for all SFOs with existing licensing exemptions to confirm their ability to comply with the new Qualifying Criteria and notify the MAS of the same.
The existing licensing exemption that an SFO has been relying on prior to the implementation of the new SFO framework would either be withdrawn upon the SFO’s filing of the requisite notification to MAS, or, at the end of the transitional one-year period, whichever is earlier. SFOs that have filed the notification with MAS are allowed to continue operating in Singapore without the need to obtain MAS’ acknowledgement. SFOs that are unable to meet the Qualifying Criteria (and are thus unable to file the notification), and continue to carry on business in fund management after the transitional one-year period will be considered to be in breach of the SFA.
The MAS will provide further details on the effective date of implementation, revised legislation and mode of submission for the initial notification and annual return prior to the implementation of the SFO framework.
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