MAS Finalises Licensing Exemption Framework for Single Family Offices

The Monetary Authority of Singapore (“MAS”) announced that the revised framework for Single Family Offices (“SFOs”) took effect on 15 June 2026. The framework introduces a simplified, structure-agnostic class exemption from licensing under the Securities and Futures Act 2001 (“SFA”) for qualifying SFOs operating in Singapore. The operative conditions are set out at paragraph 5(1)(ba) of the Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations (“SFR”). The framework follows MAS’s public consultation in July 2023 and its response to industry feedback published on 6 November 2024.

Background and Purpose

Previously, SFOs that did not fall neatly within existing class exemptions, such as the related corporation exemption, often sought case-by-case licensing exemptions from MAS. 

MAS introduced the class exemption to strengthen surveillance and defence against money laundering (“ML”) risks in the SFO sector and harmonise the exemption criteria for all SFOs operating in Singapore.  

Class Exemption and Qualifying Criteria

An SFO must satisfy the following requirements to operate in Singapore under the new class licensing exemption. 

A. Commencement of Business Requirement 

At the date of commencement of the SFO’s business in fund management, the SFO must carry on that business for, or on behalf of, one or both of the following: 

• one or more family members (each a “founding member”) of a single family; and/or 
• an eligible entity whose assets at that time originated from one or more founding members of that family. 

“Family member” refers to all lineal descendants of a common ancestor (living or deceased), including current or former spouses, adopted children, stepchildren, parents-in-law and siblings-in-law.

The common ancestor must not be more than five generations removed from the youngest generation that established the SFO in Singapore. All family members within the five generations can be served by the SFO, and future generations may subsequently be included and served.

B. Scope of Fund Management 

The SFO may only conduct fund management for or on behalf of:

• family members;
• an eligible entity; and/or
• key employees of the SFO.

“Eligible entity” means a body corporate, body unincorporate or trust that meets the following requirements: 

• all of its assets originate from one or more family members and/or a key employee of the SFO; and
• the persons who benefit from the management of its assets consist only of a family member, a key employee of the SFO and other permitted persons under the SFR. 

“Key employees” comprise executive directors, the chief executive officer, the chief financial officer and investment professionals (i.e. an individual employed by the SFO to manage, research or deal in products which are part of the SFO’s assets under management, for investment purposes on behalf of the SFO), and persons who formerly held such roles who have ceased to be appointed or employed by the SFO for a period of one year or less. 

Assets originating from key employees must not exceed 10% of the total value of the SFO’s assets under management in aggregate.

C. Ownership and funding 

The SFO must satisfy the following shareholding requirements:

• the shares in the SFO are held directly only by one or more of: family members, key employees of the SFO, qualifying trusts, qualifying foundations, and entities whose ownership is held only by one or more of the foregoing persons (a “Qualifying Entity”);
• the shares in the SFO are held indirectly only by a Qualifying Entity; and 
• the total direct and indirect shareholding in the SFO of its key employees who are not also family members must not exceed 10%.

The SFO may be held via a trust, foundation or any other legal structure, provided that the funding of the SFO originates exclusively from:

• members of the same family, whether directly or indirectly, and
• key employees who are permitted to own a non-controlling stake of up to 10%.

D. Incorporation

The SFO must be incorporated in Singapore.

E. Banking relationship

The SFO and its fund vehicle(s) must each open and maintain a bank account with an MAS-licensed bank. A foreign-incorporated fund vehicle may open and maintain an account with an MAS-licensed bank in Singapore, or with a regulated bank in a jurisdiction that complies with anti-money laundering and countering of financing of terrorism (“AML/CFT”) requirements consistent with the standards set by the Financial Action Task Force (“FATF”).

F. Notification Requirements

New SFOs must file a Notice of Commencement of Business (“the Notification”) with MAS within 14 days of commencement of operations in Singapore. 

Existing SFOs that commenced business before 15 June 2026 and are currently operating under the related corporation exemption under paragraph 5(1)(b) of the Second Schedule to the SFR or an exemption under section 99(1)(h) of the Securities and Futures Act, must file a Notice of Continuation of Business (the “Notification”) by 15 June 2027. 

The Notification must include:

• SFO particulars, including full name, UEN, financial year end and total assets managed;
• bank particulars for the SFO and its fund vehicle(s), including the names of the banks with which the SFO and fund vehicle(s) have opened and maintained accounts;
• name and email address of the SFO’s designated contact person; and
• a signed declaration furnished on the SFO’s letterhead, and submitted in PDF format.

There is no requirement for an SFO to seek legal advice, furnish a legal opinion, or provide the name of its legal adviser as part of the Notification. This represents a significant departure from MAS’s original consultation proposal, which contemplated a requirement for a legal opinion. 

A system-generated acknowledgement will be issued to SFOs that successfully file a Notification.

G. Annual Reporting Requirements

SFOs must submit an annual return within four months from the end of the SFO’s financial year. The first annual return is submitted in respect of the SFO’s current financial year, within four months from the end of that year. There is no requirement to submit an annual return in respect of the SFO’s previous financial year before filing the Notification. MAS has stated that no further extension will be granted for lodging annual returns. 

The annual return must include:

• key particulars of the SFO (including total assets under management);
• information on the bank(s) with which the SFO and its fund vehicle(s) have opened and maintained accounts;
• name and email address of the designated contact person; and 
• a declaration that the SFO continues to satisfy all conditions and restrictions in paragraph 5(1)(ba) of the Second Schedule to the SFR and that all information provided in the annual return is true and correct.

H. Designated Contact Person 

SFOs must have at all times an employee who is ordinarily resident in Singapore (i.e. primarily based in Singapore with a Singapore residential address) as the SFO’s point of contact with MAS for the purposes of any matters relating to the exemption.

Transitional Arrangements

Existing SFOs have a transitional period of one year from 15 June 2026 (i.e. until 15 June 2027) to satisfy the conditions under the new class licensing exemption and file the Notification. The previous licensing exemption that an SFO had been relying on will be withdrawn upon lodgement of the Notification, or at the end of the transitional period, whichever is earlier.

MAS will generally not grant case-by-case exemptions unless there are exceptional reasons. In recognition that SFOs have various ownership structures and manage a range of investment structures, the licensing exemption has been designed to be structure agnostic to cater to a wide range of SFOs.

Key Changes from Consultation

The operative framework reflects several notable refinements from MAS’s original consultation proposals:

• no requirement to obtain or furnish a legal opinion, or to provide the name of a legal adviser;
• Notification deadline extended to 14 days from commencement (from the originally proposed 7 days);
• annual return deadline set at four months from financial year end (not 14 days after calendar year end);
• transitional period extended to one year (from the originally proposed six months); and
• financial institution relationship requirement narrowed to bank account relationships with MAS-licensed banks, with specific treatment for foreign-incorporated fund vehicles.

Action Required

Existing SFOs should review and consider whether they can satisfy the conditions under the new class licensing exemption. Key steps include:

• confirming the scope of fund management activities and key employee participation;
• ensuring that the SFO and its fund vehicle(s) maintain accounts with MAS-licensed banks (or, for foreign-incorporated fund vehicles, an MAS-licensed bank in Singapore or a regulated bank in an AML/CFT-compliant FATF jurisdiction);
• identifying the SFO’s designated contact person (who must be primarily based in Singapore with a Singapore residential address);
• preparing the signed declaration and other particulars required for the Notification; and
• noting the annual reporting obligations and the four-month submission deadline from financial year end.

New SFOs commencing operations in Singapore on or after 15 June 2026 must file the Notification within 14 days of commencement. SFOs should also prepare to submit annual returns within four months from financial year end and ensure they can continue to confirm compliance with the exemption conditions.