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Variable Capital Company? MAS wants input on their AML requirements

1 Preface

1.1 The Monetary Authority of Singapore (MAS) is introducing a Notice to variable capital companies (VCCs) on anti-money laundering and countering the financing of terrorism (AML/CFT). The proposed VCC AML/CFT Notice is attached as Annex B of this consultation paper. These requirements draw reference from international best practices and the Standards set by the Financial Action Task Force (FATF), the global standard-setter for measures to combat money laundering (ML), terrorism financing (TF), and proliferation of financing.

1.2 MAS invites comments from prospective VCCs and their managers1, eligible financial institutions2, and any other interested parties on the proposed VCC AML/CFT Notice.

Please note that all submissions received will be published and attributed to the respective respondents unless they expressly request MAS not to do so. As such, if respondents would like:

(i) their whole submission or part of it (but not their identity), or

(ii) their identity along with their whole submission,

to be kept confidential, please expressly state so in the submission to MAS. MAS will only publish non-anonymous submissions. In addition, MAS reserves the right not to publish any submission received where MAS considers it not in the public interest to do so, such as where the submission appears to be libellous or offensive.

What is a Variable Capital Company?

The VCC Act was passed by Parliament on 1 October 2018, introducing a new corporate structure in Singapore that is designed for collective investment schemes (CISes). The Registrar of Companies, the Accounting and Corporate Regulatory Authority (ACRA), will be the Registrar for VCCs. ACRA will administer the VCC Act and subsidiary legislation while AML/CFT obligations of VCCs under the proposed VCC AML/CFT Notice will come under the purview of MAS.

And the notice contains the due date (May 30th), the email reply address and a suggested reply format.


MAS Consultation Paper

Categories: Anti-Money Laundering Consultations MAS Updates


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