Singapore · Managed KYC services
We complete onboarding, remediation and overdue KYC reviews for Singapore funds, asset managers, brokerages, administrators and banks. Our compliance reviewers work under your AML policy, document the evidence and return each case for your team’s decision.
Your AML policy · Qualified human review · Your team keeps approval
Managed KYC
Engage us for a one-off remediation project or recurring KYC work. We agree the case population, evidence requirements and escalation route before work begins.
01 · Onboarding
We work customer, investor and counterparty cases: reviewing identity documents, tracing ownership through holding companies and screening the relevant parties. You receive the evidence, risk assessment and open questions your authorised approver needs.
02 · KYC remediation
Missing ownership evidence, unsupported source of wealth or unresolved screening hits can leave a file open for months. We work the agreed backlog and record what is resolved, what is missing and what needs escalation.
03 · Periodic reviews
We refresh KYC records, update screening and reassess risk under your policy. Reviews follow your risk-based schedule and agreed triggers, including ownership changes and new adverse information.
MAS AML/CFT · Define the responsibility
We confirm the requirements that apply to your entity and activities before work starts. Your AML/CFT policy sets the checks, risk methodology and escalation rules. Your authorised team keeps acceptance and reporting decisions.
For fund managers and VCCs, the responsibilities are distinct. MAS Notice SFA04-N02 covers capital markets intermediaries, including licensed fund managers. A Singapore VCC has its own duties under Notice VCC-N01 and must appoint an eligible financial institution to perform the required AML/CFT checks. Its board retains ultimate responsibility.
Fund & VCC guideMAS sets out the VCC and EFI responsibilities in its guidelines to Notice VCC-N01. Our MAS AML/CFT guide explains how to translate the framework into file checks and oversight records.
What you receive
Each file records what we checked and why we reached the conclusion. Outstanding evidence stays visible in the handover.
Included in the file
An indexed record of the customer, investor or counterparty, relevant connected parties and beneficial ownership, with the evidence behind each verification step.
Included in the file
Sanctions, PEP and adverse-media results, including the reviewer’s reasoning when a potential match is cleared or escalated.
Included in the file
A documented risk assessment, source of funds and wealth evidence where required, and an exception log for information still outstanding.
Included in the file
Reviewer notes and a traceable record of work for your authorised team to accept, reject or request further evidence.
The process
01 · Scope
Tell us the entity type, backlog size and target date. We agree your policy, deliverables, access and price before you send case documents.
02 · Work & review
Agents organise documents and run the first pass. Qualified compliance reviewers check the evidence and reasoning, then escalate unresolved or higher-risk cases.
03 · Handover
Receive reviewed files and an exception log. Your authorised team makes acceptance and escalation decisions. Recurring work follows the schedule you approve.
If your administrator already performs KYC, Shadow KYC can provide a separately scoped review of its files. Singapore managers of Cayman funds can also use our Cayman KYC services, with the fund’s Cayman obligations assessed separately.
Questions
Scope, pricing and the decisions your Singapore team keeps.
Scope your KYC backlogCustomer, investor and counterparty onboarding, KYC remediation and periodic or trigger-event reviews for Singapore funds, asset managers, brokerages, administrators and banks. This includes fund managers and VCC structures. We agree the entity, applicable requirements, policy and case population before starting. Our service covers the operational work specified in the engagement.
Yes. We scope operational KYC support around the VCC’s appointed eligible financial institution and approved AML/CFT policy. This engagement does not replace the required EFI appointment. The VCC’s board retains ultimate responsibility, and authorised decision-makers keep customer acceptance and escalation decisions.
No. Your firm retains responsibility for its AML/CFT obligations and oversight of service providers. We document the work and escalate exceptions under the agreed policy. Your authorised team retains acceptance, high-risk approvals and suspicious transaction reporting decisions.
Yes. We can agree a separate Shadow KYC review of administrator-held files, assess independence and report file-level gaps. The scope is file testing and remediation findings; a programme-wide independent AML audit requires a broader engagement.
No. We provide KYC and AML operational support. MAS does not approve each case file through our service. Compliance depends on your entity’s obligations, controls and decisions, including work outside our engagement.
We quote against the case count, ownership complexity, available evidence and review scope. Share your target date and we confirm the price, delivery schedule and responsibilities for missing documents in writing. Hosting region, access and retention terms are also agreed before file transfer.
Discuss your files
Bring the case count, entity type and target date. We’ll confirm the scope, price and delivery schedule in writing.
Or send the case list to [email protected]