Singapore’s Registered Fund Management Company (RFMC) regime ended on 1 August 2024. If you are looking for regulatory requirements for registered fund managers, first check whether the guidance describes a current licence category. An old RFMC checklist is no longer a sound starting point for operating a Singapore fund management business.
Today, Singapore managers generally need a capital markets services (CMS) licence for fund management unless an exemption applies. The requirements cover who can manage the business, its financial resources, how it handles client assets, regulatory submissions and anti-money laundering and countering the financing of terrorism (AML/CFT).
This guide focuses on Singapore, particularly managers serving accredited and institutional investors. Requirements vary by jurisdiction, registration category and activity. It provides general information, not legal advice; confirm your firm’s obligations with qualified advisers and the current regulatory texts.
Start with the jurisdiction and legal entity
“Registered fund manager” does not describe one worldwide regulatory status. Identify the manager’s home jurisdiction, where it conducts business, the fund’s domicile and where investors are approached. Each can introduce separate obligations.
In Singapore, the 2024 amendment regulations removed the RFMC category. In the United States, a private fund’s adviser generally registers with the SEC or a state securities regulator unless an exemption applies. The SEC’s explanation distinguishes adviser registration from the fund’s own status. Malaysia has its own Securities Commission licensing and registration framework. Singapore thresholds should not be applied to either jurisdiction.
The manager and the fund also need separate assessments. A Singapore manager running a Cayman fund must consider both entities’ obligations. A Singapore variable capital company (VCC) has its own AML/CFT duties under Notice VCC-N01, including an eligible financial institution appointment. Our MAS AML/CFT guide for fund managers and VCCs explains that division of responsibility.
Choose the current Singapore licence category
The Monetary Authority of Singapore (MAS) describes three fund management categories:
- Retail LFMC: a licensed fund management company that can serve all types of investors, including retail investors.
- A/I LFMC: a licensed fund management company restricted to accredited and institutional investors.
- VCFM: a venture capital fund manager serving accredited and institutional investors and managing funds that meet the specific venture capital eligibility criteria.
A small manager does not qualify for the VCFM regime simply because it has few clients or limited assets. The funds and investments must meet the criteria in Appendix 4 of MAS’s licensing guidelines, SFA 04-G05.
For a former RFMC, use the current CMS licence and its conditions as the starting point. Check permitted activities, investor restrictions and any firm-specific assets-under-management limit. Repeal of the RFMC regime did not remove conditions attached to an individual firm’s licence.
The overview below uses the A/I LFMC framework. Retail managers and VCFMs must check their category-specific provisions. A licensing exemption also needs a documented basis; it does not automatically remove every other regulatory obligation.
Maintain capital, staffing and compliance arrangements
Under paragraphs 3.13–3.14 of SFA 04-G05, the base capital threshold for the A/I fund management activity category is S$250,000. The guidelines specify S$1 million for managing collective investment schemes offered to investors other than accredited or institutional investors, and S$500,000 for non-scheme fund management for such customers.
These are ongoing base capital requirements, not application fees or complete operating budgets. LFMCs must also maintain financial resources of at least 120% of their total risk requirement under the applicable financial rules. The simplified VCFM framework must be assessed separately.
Appendix 1 sets staffing and competency requirements. For an A/I LFMC, these include:
- A full-time, Singapore-resident CEO with at least five years of relevant experience, including managerial or supervisory experience.
- At least two directors with at least five years of relevant experience each, including at least one full-time, Singapore-resident executive director. At least one executive director needs five years of portfolio-management experience relevant to the intended investments.
- At least two Singapore-based, full-time relevant professionals with five years of relevant experience, and at least two full-time representatives residing in Singapore.
These roles can overlap where appropriate and where the person meets each role’s requirements. They should not be added together mechanically as separate hires. Fitness, propriety and applicable representative competency requirements also matter.
Compliance arrangements depend on the business’s size and activities. Appendix 2 distinguishes A/I LFMCs below S$1 billion in assets under management from those at or above that threshold and retail managers. Read the conditions for internal, group or external compliance support before choosing a staffing model. Paragraph 3.15 leaves ultimate responsibility with the CEO and directors even where a third party provides support.
Cover investment operations as well as AML
Fund manager compliance extends beyond investor onboarding. Sections 3 and 4 of SFA 04-G05 address risk management, internal audit, independent annual audit and ongoing business conduct.
For an LFMC, assess independent custody, independent valuation and reporting to customers against the applicable rules and any available exceptions. Keep conflicts of interest under review and disclose the investment strategy, risks, fees, valuation approach and relevant service providers. Material changes can require updated disclosures.
An annual audit alone does not satisfy the independent valuation requirement. Paragraph 4.1.2 makes that distinction explicit. Separate the controls for daily operations from the checks performed by the external auditor.
MAS’s May 2026 risk management information paper sets out supervisory expectations for governance, investment due diligence, new fund launches and ongoing monitoring. It calls for defined responsibilities and documented assessments, including oversight of service providers.
Keep a regulatory inventory that also covers applicable technology, business continuity, data protection, outsourcing and other requirements relevant to your strategy. The licensing guidelines and this article are not exhaustive. Laws, regulations, notices and licence conditions impose obligations; guidelines and information papers explain supervisory expectations and should be read alongside them.
Build a calendar for returns and business changes
The MAS Compliance Toolkit, revised on 29 May 2026, provides separate documents for LFMCs and VCFMs. In the LFMC toolkit, items 37–38 list:
- Quarterly financial returns: Forms 1 and 2, within 14 days from the end of each quarter.
- Audited annual financial returns and the auditor’s report: within five months from the financial year-end, using the specified forms and supporting documents.
Other obligations are triggered by events. Changes to controllers, key appointments, regulated activities or capital can require approval or notification. Breaches and reportable incidents have their own triggers and timelines. Check the relevant requirement before making the change; an annual return cannot substitute for prior approval.
As an operating practice, give each obligation an owner, a reviewer, a deadline and a link to its source. Retain the submitted version and acknowledgement. The toolkit itself says it is not exhaustive and excludes fund-level requirements and reporting obligations outside the Securities and Futures Act.
Turn AML/CFT requirements into reviewable KYC files
Notice SFA04-N02 is the starting point for a licensed fund manager’s AML/CFT requirements. It covers risk assessment, customer due diligence (CDD), records, suspicious transaction reporting, internal controls, audit and training. Its definition of money laundering includes proliferation financing.
Translate the notice and accompanying guidelines into the firm’s approved policy. Know your customer (KYC) work should establish the customer’s identity, ownership and control, the purpose of the relationship and the risks that affect acceptance and ongoing review.
Our suggested file checklist is:
- Identity and verification evidence for the customer and relevant parties, including beneficial owners.
- An ownership chart connected to source documents, with gaps or inconsistencies identified.
- Sanctions, politically exposed person (PEP) and adverse-media screening results, with reasons for clearing or escalating potential matches.
- A documented risk assessment and enhanced due diligence where required, including source-of-funds and source-of-wealth evidence as applicable.
- The reviewer’s findings, outstanding evidence, approval decision and the next review date or trigger.
Accredited-investor status answers an investor-classification question. It does not, by itself, establish that a customer is low risk for AML/CFT purposes. Apply the notice’s conditions for any simplified treatment, enhanced measures and different PEP categories.
Keep CDD information current through risk-based periodic and trigger-event reviews, alongside ongoing monitoring. Do not treat every customer as subject to one universal annual refresh cycle. Escalate suspicious activity through the firm’s reporting process.
Paragraph 11 of the notice generally requires relevant relationship CDD records to be retained for at least five years after the relationship ends, and transaction records for at least five years after the transaction completes. Apply the relevant starting point for each record type, other legal requirements and any investigation-related retention request or order. A file stored by a provider still needs to be retrievable when the responsible firm needs it.
Define what outsourced KYC work covers
An outsourced team can prepare and review files, but the responsible firm must retain oversight. Distinguish an operational outsourcing arrangement from third-party reliance under paragraph 9 of SFA04-N02, where a firm relies on another eligible institution’s CDD. Those reliance conditions include access to evidence and obtaining the CDD information; paragraph 9.3 prohibits reliance on a third party for ongoing monitoring. Paragraph 9.5 preserves the firm’s responsibility.
Before appointing a provider, agree the entity and files covered, the policy to apply, evidence requirements, escalation routes, access controls and retention terms. Identify who obtains missing documents and who makes acceptance, higher-risk approval and suspicious transaction reporting decisions. Monitor delivery and record how exceptions are resolved.
For a VCC, scope KYC support around its required eligible financial institution arrangements. For administrator-held files, define the review’s independence and reporting line. File testing can support oversight, while a programme-wide independent AML audit needs its own scope.
Choose software or managed KYC for the work you need
AgentKYZ supports the operational KYC work within this wider compliance framework. Use AgentKYZ’s KYC software with your own compliance team, or engage our Singapore managed KYC service for onboarding, remediation and overdue periodic reviews.
The workflow starts with your AML policy and review requirements. Agents organise documents, trace ownership, run screening and prepare findings. In a managed engagement, qualified compliance reviewers check the evidence and reasoning, record unresolved questions and return reviewed files for your authorised team’s decision.
The handover includes identity and ownership evidence, screening rationale, a risk assessment and an exception log. This gives your approvers a record they can follow and a defined list of work still outstanding. Your firm retains final acceptance and escalation decisions within its wider compliance programme.
If your administrator already performs KYC, ask about a separately scoped Shadow KYC review of its files. If the bottleneck is an internal review queue, the software may fit your existing staffing model. A managed engagement suits a defined backlog or recurring work that needs additional review capacity.
To scope the work, bring your licence category, fund domiciles, case count, ownership complexity and target date. Discuss your Singapore KYC requirements with AgentKYZ and agree the deliverables, price, data arrangements and decision responsibilities before transferring case documents.