Webinar identity and tentative rollout
These 40slides were presented on 15and 30 April 2025. The timeline describes tentative May publication of subsidiary legislation and registered-CSP guidelines, tentative June commencement and a six-month transition for new entrants, illustrated as registration by December 2025. The deck’s tentative milestones are historical planning information, not independent confirmation of the final commencement dates. Its main subjects are registration scope, CDD, remote transactions, fit-and-proper nominee directors and the 2024 company/LLP amendments.
Which businesses fall within CSP registration
Entities carrying on corporate-service business in and from Singapore must register. The deck includes forming local or foreign entities for others, acting or arranging people as directors or nominee shareholders, acting as company secretary by way of business, transacting with ACRA for others, providing registered/business addresses and designated transactions relating to accounting services. Several categories are marked as new. The business and service substance determines scope; incorporation filing is only one category and registration is not limited to firms doing that transaction.
Address services versus genuine premises rental
Registration scope includes registered offices meeting Companies Act 142, business addresses where a customer operates and correspondence addresses where the customer can be contacted in writing. Virtual and shared-office providers may fall within it. A landlord simply leasing dedicated physical premises does not need registration merely because the tenant uses the address for these purposes. By contrast, providing an address without fixed space or correspondence access without physical presence falls within the illustrated address-service cases. Clearly document the arrangement, including dedicated-space tenancy terms rather than assuming every landlord relationship or shared-office arrangement is exempt.
CDD before service and during the relationship
Perform CDD before any corporate service and when there is ML/TF/PF suspicion or doubt about earlier information’s accuracy or adequacy. Identify and verify customers and beneficial owners, obtain the relationship’s purpose and intended nature and conduct prescribed detection/prevention measures such as screening. Retain documentation for five years and keep customer information current through monitoring. Good practices include screening relevant parties against commercial databases and inspecting valid government identification with retained copies. Observed failures include inadequate risk assessment, missed beneficial owners, unverified particulars, stale information and missing or inadequate records.
Third-party categories and incomplete CDD
The deck’s third-party categories are advocates and solicitors, Singapore financial institutions, public accountants and, for a registered CSP, branches, subsidiaries, holding companies and related corporations. Listing these categories is not a complete explanation of all reliance conditions. If CDD cannot be completed, decline service and do not establish a relationship; terminate ongoing service, document why measures were not completed and consider an STR. Inability to complete verification is therefore a service-decision issue, not merely a missing document to be deferred indefinitely.
Suspicion and STR timing
Consider an STR where CDD cannot be completed or there are reasonable grounds to suspect property is connected with ML/TF/PF. The webinar instructs prompt filing as soon as reasonably practicable after suspicion is established, no longer than five business days. Where a transaction has a legitimate explanation and does not warrant reporting, document why no report is filed. The five-business-day instruction is not permission to continue suspicious service without completing required CDD, and a legitimate explanation should be recorded rather than assumed.
Remote incorporations and shelf-company transactions
Where a customer is not physically present for identification, take specific adequate measures to address higher risk using additional documents, data or information. For incorporation or transfers of management/ownership or sale of shelf companies, a live video call is required with at least one proposed non-nominee director, or a proposed member holding at least 50% voting rights, or an individual authorised representative of such a proposed corporate member. A third-party verification platform or notarised documents cannot replace this live call. The 50% requirement belongs to the member alternative, not the director alternative.
Remote director consent and Form 45
For a proposed director who is not physically present, take all reasonable measures to ensure the person has consented. Ensure the proposed director signs Form 45 in the Second Schedule to the Companies Regulations and retain a copy. The CSP must not sign it on the director’s behalf. These controls address impersonation and consent separately from the live-video requirement for specified transaction types.
Nominee-director business and suitability
A person cannot act as nominee director by way of business unless a registered CSP arranges appointment, and that CSP assesses fit and proper status. Business indicators include a service business established for that purpose, advertising/referrals, gain and systematic continuing activity. Assess fraud/dishonesty or relevant convictions in Singapore or abroad, undischarged bankruptcy, previous conduct and company compliance, and competency/capacity considering experience and existing commitments. The guide generally looks at the past five years, including disqualification, debarment, composition offers and prosecution. Physical or mental limits, inability to understand duties or too many roles can undermine suitability. More than 50 nominee directorships calls for capacity assessment and a recommendation for additional training, not an automatic statutory ban stated in this deck.
Relevant offences and register changes
The offence examples include CSP Act 25, CDSA50–57, the Terrorism (Suppression of Financing) Act, United Nations Act regulations and Companies Act 157; the CSP glossary supplies the full list. For controllers, the amendment changes initial RORC maintenance from within 30 days to incorporation/registration date, and adds annual notices to confirm particulars and updates. Companies and foreign companies must lodge all nominee-director/shareholder register particulars and later updates in ACRA’s central register; nominee status becomes publicly available. The deck encourages CSPs to remind customers to maintain accurate registers. It does not say all nominator particulars become public merely because nominee status is public.
Further risk and reporting publications
The deck points to 2024 legal-person, terrorism-financing and money-laundering risk assessments, proliferation-financing assessment, FATF beneficial-ownership and proliferation-risk guidance, the risk-based approach for trust/company service providers, the national terrorism-financing strategy, trade-based laundering developments, targeted sanctions, IMC-TD and STR-reporting guidance. These sources support the service-specific risk assessment beyond a checkbox exercise. The webinar provides a framework and selected examples, while its own publication references are intended for deeper risk and implementation detail.
Official source
This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.
Read the official PDF ↗