Corporate requirements
- - Singapore entity with clear proposed activities and product scope
- - Business plan, financial resources, compliance arrangements, AML/CFT program, and risk management framework
- - Representative framework and supervision model
- - Client classification and marketing controls for retail, accredited, and institutional clients
Application journey
- 1. Confirm whether the activity is fund management, dealing, corporate finance advice, custody, REIT management, product financing, or another SFA-regulated activity.
- 2. Check whether a full CMS licence, registered fund management route, exemption, or representative arrangement is available.
- 3. Prepare MAS application materials, controllers and directors information, financials, compliance program, AML/CFT controls, and representative arrangements.
- 4. Submit through the relevant MAS or government licensing channel and respond to follow-up questions.
- 5. Before launch, verify the firm and representatives in MAS directories and test client-classification controls.
Documents and controls
- - People and competence: Shows that named individuals can perform or supervise the regulated work.
- - Ownership and controllers: Explains who owns, controls, funds, and benefits from the applicant.
- - Governance and accountability: Allocates decision rights, oversight, senior responsibility, committees, and escalation.
- - Capital and financial resources: Shows runway, prudential planning, and resource adequacy for the proposed permissions.
- - AML/CFT and financial crime: Shows customer due diligence, sanctions, monitoring, suspicious activity, and escalation controls.
- - Compliance framework: Turns rules into owned, scheduled, evidenced operating controls.
- - Custody and client assets: Explains whether client assets are held, controlled, safeguarded, deducted from, or avoided.
- - Outsourcing and vendors: Shows that outsourced work is selected, supervised, escalated, and replaceable.
- - Cyber and technology controls: Shows platform resilience, access control, business continuity, incident response, and data protection.
- - Complaints and conduct: Shows conduct risk ownership, customer handling, and escalation for complaints or disputes.
- - Regulatory reporting: Shows that recurring reports, filings, amendments, attestations, and register changes are owned.
- - Financial forecasts: Connects business plan, revenue assumptions, costs, capital, and runway to the applicant entity.
- - Wind-down and exit planning: Shows how clients, assets, records, complaints, and obligations would be handled if the business stops.
Capital and timeline
Capital and financial resource expectations depend on activity, client type, custody, and the specific licence or exemption path.
Timeline estimate: Typically 4 to 9+ months depending on route and readiness.
Common bottlenecks
- - Assuming accredited or institutional clients remove all licensing questions
- - Weak explanation of investment strategy, risk management, or outsourced functions
- - Unclear representative arrangements and supervision
- - Marketing plans that drift into retail or public solicitation without controls