One-year countdown: Existing SFOs evaluate how they can align with revised MAS framework
Not a ‘Singapore-only story’; moves will strengthen Apac’s proposition as a family office hub and region to deploy capital
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[SINGAPORE] While single family offices (SFOs) in Singapore now enjoy a simplified regulatory framework, existing players will need to ensure that they comply with the revised rules.
The updated framework, which took effect on Jun 15, is meant to simplify the process for SFOs to establish operations in the Republic. It also streamlines their documentation and reporting requirements.
Existing SFOs have one year to align with the Monetary Authority of Singapore’s (MAS) revised regulatory framework. This comes after a public consultation and MAS’ policy responses to industry feedback published in November 2024.
The new structure relies on three core requirements: notifying MAS, maintaining a relationship with a regulated bank and filing an annual return.
Time to adapt needed
Shaun Zheng, director of tax services at CLA Global TS, said that his team had hoped for existing family offices to be “grandfathered” into the revised framework – reducing the need for them to work on a fresh compliance exercise.
Instead, they now have to revisit their existing structures, documentation and eligibility, he noted.
“In real practical terms, clients whom we serve now are asking questions such as ‘whether we still qualify’ and ‘what extra work does this create for us’,” he said.
“Existing clients... now want formal confirmation on eligibility, funding source rules and reporting processes, among others.”
David Ng, co-founder and chief executive officer of Arki Finance, pointed out that family offices may need more time to adapt to changes in documentation, structure and ongoing compliance.
“Some family offices may need to review whether their ownership structures, investment entities, trust arrangements, foundations or charitable vehicles fall clearly within the qualifying criteria,” he said.
“More complex or multigenerational family structures may also need to assess how non-family professionals, investment vehicles or philanthropic entities are treated under the framework.”
Previously, there was no explicit cap. Under the revised framework, MAS caps assets originating from key employees at 10 per cent of the total value of the SFO’s assets under management in aggregate.
These employees are also allowed to own a non-controlling stake of up to 10 per cent. In the instance this exceeds the caps, the SFO must reassess to ensure that it meets the requirements before Jun 15, 2027. Another point relates to the annual reporting requirement.
“Even if the information required is relatively straightforward, family offices will need to ensure that they have proper internal records, a clear Singapore-based point of contact and appropriate governance processes to support ongoing compliance,” Ng said.
Noting that many SFOs are operationally lean, Christos Anagnostopoulos, head of family office solutions and advisory for Asia at Julius Baer, said they could face constraints in internal resourcing when bolstering their capabilities to put in place the right operating model and ensure sustainable, long-term effectiveness.
Wyn James, head of asset owners for the Asia-Pacific at IQ-EQ, said: “Families will need to ensure they have the right governance and reporting infrastructure in place. “The one-year transition period is sensible, but more complex multi-entity or multigenerational structures will need time to review alignment ahead of the June 2027 deadline.” Inquiries are spanning areas related to compliance, governance and regulatory matters.
PwC’s Asia-Pacific private wealth leader Anuj Kagalwala said the firm is receiving more queries as family offices digest the new filing obligations and plan for the transition period.
The team also expects an initial burst of activity, with a second wave closer to the end of the transition window, as families operationalise internal processes for filing and sign-offs.
“A common question that we have clarified for our family office clients is that MAS has confirmed there is no requirement to submit a legal opinion or disclose the name of a legal adviser as part of the notification.”
Zheng of CLA Global TS noted that inquiries could increase over the coming quarter, but he does not anticipate the revised framework to significantly increase the number of SFOs setting up in Singapore.
A regional play, not just a local one
The number of SFOs in the Republic exceeded 2,000 by end-2024, based on the latest figures provided by MAS.
Advisers framed the reform as part of a wider contest for family office capital across Asia, rather than a Singapore-only story.
With jurisdictions competing on speed, clarity and reliability rather than tax or regulatory lightness, Singapore is positioning itself as efficient and transparent, not laissez-faire, IQ-EQ’s James noted.
“Importantly, this is strengthening the Asia-Pacific’s proposition overall, not just one market. Many sophisticated families are increasingly looking at multijurisdiction models across the region, rather than a single ‘hub’ approach.”
Zheng similarly noted that this is another hopeful step towards attracting more serious and well-structured family offices.
“(This reinforces) Singapore’s position as a trusted hub and gateway for capital deployment into the Asia-Pacific region while being cognisant of other jurisdiction players within the (wider) region – (such as the) United Arab Emirates, Hong Kong and the emerging Central Asia region – vying for the family office market,” he said.
Overall, the move is perceived more as accelerating momentum than fundamentally changing direction.
“The biggest impact will be on families that were previously undecided, comparing jurisdictions and waiting for regulatory certainty,” observed James.
“What changes here is not just the rules, but (also) the experience. The set-up process becomes faster, clearer and easier to navigate.”
Key takeaways for SFOs
Anagnostopoulos said: “The key takeaway for families and their advisers is that checks and balances – such as the banking requirement and annual declarations – are now embedded in the ongoing relationship and process, rather than concentrated in a one-time approval.”
Under the licensing exemption framework, both the SFO and its Singapore-incorporated fund vehicle are required to open and maintain accounts with MAS-licensed banks in Singapore, according to the authority.
Lenders are required to conduct anti-money laundering (AML) and countering the financing of terrorism checks on SFOs and their fund vehicles.
The customer due diligence and ongoing monitoring checks conducted on an SFO would be subject to the bank’s risk-based approach when it establishes a business relation with its customer, MAS said.
James said that the revised framework is genuinely pragmatic – low friction at entry, but with enough oversight to maintain credibility.
“This is a clear shift away from case-by-case approvals to a standardised, predictable pathway,” he noted. “For families comparing jurisdictions, that clarity and speed of execution are often more important than marginal cost differences.”
He added that the structure‑agnostic approach lets families keep using trusts, foundations or layered holding structures without needing to reshape them around regulatory requirements.
Ryan Lin, director of Bayfront Law, said that there is also a shift towards a notification-based framework, under which an SFO can self-assess its eligibility and submit a notification to MAS without requiring prior approval or a legal opinion.
The timing follows Singapore’s strongest endorsement yet on financial crime enforcement.
In May, the country received the highest monitoring rating from global watchdog Financial Action Task Force (FATF) for its fight against financial crime.
Zheng noted that the requirement to maintain banking relationships with MAS-regulated and/or FATF-compliant institutions particularly strengthens trust among banks and counterparties.
Lin noted: “The new framework seems to be consistent with Singapore’s broader objective of facilitating legitimate wealth flows while maintaining high regulatory standards.
“This provides greater certainty and reduces friction in the onboarding process, while preserving robust AML and governance safeguards.”
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