Register of registrable controllers

With effect from 31 March 2017, a new law was introduced to require companies, foreign companies, and LLPs (unless exempted) in Singapore to maintain a Register of Registrable Controllers. 


The aim of this law is to make ownership and control of corporate entities more transparent and to reduce opportunities for the misuse of corporate entities for illicit purposes.


The key points of the law are as follows:

  1. It is to be maintained at prescribed places such as at the registered office address or the registered office of the registered filing agent.
  2. The register can be maintained in paper or electronic format.
  3. Entities will have to declare the location of the company’s register of registrable controllers when filing the annual returns or annual declaration.
  4. Entities can discharge their duties by sending notices to the relevant parties and recording their particulars, as well as sending further notices to any other parties that have been revealed as potential controllers. Notices can be sent and replies may be received, in electronic or hard copy format. Entities will not be liable should recipients of these notices fail to respond or provide inaccurate responses.
  5. A controller is required to provide and update information to the entities.

For more details, get in touch with a corporate secretary in Singapore!

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ACRA Cancels Registration of Filing Agent and Qualified Individual for AML/CFT Breaches

The Accounting and Corporate Regulatory Authority (ACRA) had cancelled the registrations of filing agent (RFA) and qualified individual (RQI) on 18 January 2024. The registrations were cancelled in view of breaches of anti-money laundering and countering the financing of terrorism (AML/CFT) controls under the ACRA (Filing Agents and Qualified Individuals) Regulations 2015 (the “ACRA Regulations”).

Some of the basic AMT/CFT controls that a RFA and RQI are required to exercise are as follows:

(a) perform additional customer due diligence measures when a customer is not physically present during onboarding;

(b) inquiring if there exists any beneficial owner in relation to some of its customers; and

(c) perform risk assessments i

RQIs and RFAs provide corporate secretarial services for business entities, such as helping customers to incorporate companies, file annual returns and fulfil other filing requirements under the Companies Act 1967 or other Acts under ACRA’s purview. RQIs and RFAs are required to perform customer due diligence measures in accordance with the ACRA Regulations, and conduct their business in such a manner as to guard against the facilitation of money laundering and the financing of terrorism. RQIs and RFAs must also satisfy statutory requirements such as being fit and proper persons, to be registered or continue to be registered.

RQIs and RFAs who breach their statutory obligations may be subject to enforcement actions, such as financial penalties of up to $10,000 or $25,000 per breach respectively or have their registrations with ACRA suspended or cancelled.

Therefore, RQIs and RFAs play an important role in helping to detect and combat illicit activities.

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