(Updated on 20 May 2025)

Singapore’s Corporate Service Providers (CSP) Act 2024 was passed by Parliament on 2 July 2024, and the Corporate Service Providers Regulations 2025 will come into effect on 9 June 2025, marking a significant step in strengthening the nation’s anti-money laundering, countering the financing of terrorism, and proliferation financing (AML/CFT/PF) framework. The Accounting and Corporate Regulatory Authority (ACRA) has released Guidelines for Registered Corporate Service Providers, to guide compliance with these new requirements.

For Corporate Service Providers (CSP) in Singapore, these changes underscore the need for robust compliance measures to meet heightened regulatory expectations and maintain Singapore’s reputation as a trusted global financial hub.

This article outlines the key updates in the CSP Act 2024 and CSP Regulations 2025, highlights the essential obligations for CSP under the Regulations and Guidelines, and offers practical steps for CSP to prepare.

Key Changes under the CSP Act 2024 and CSP Regulations 2025:

Mandatory Registration as CSP with ACRA
Nominee Director and Shareholder Requirements
AML/CFT/CPF Obligations for CSP
Increased Penalties for Non-Compliance

1. Mandatory Registration as Corporate Service Providers (CSP) with ACRA

All business entities providing corporate services in or from Singapore must register with ACRA as registered CSP, regardless of whether they file transactions with ACRA, and have at least one registered qualified individual (RQI).

Entities offering the following services are required to register as CSP

Business entities formation;
Acting as or arranging nominee directors or shareholders;
Transacting with ACRA on behalf of other persons or as a secretary of a company by way of business;
Providing registered office addresses or a business address; or
Performing designated activities relating to the provision of accounting services (refer to the details below).

Designated Activities and Accounting Services

buying or selling of real estate;
management of client monies, securities or other assets;
management of bank, savings or securities account;
organisation of contributions for the creation, operation or management of companies;
creation, operation, or management of legal persons or arrangements, or buying and selling of business entities.

Application Fee

The application fee for registration or renewal of registration as a CSP is S$400 for 2 years of registration.

Transition Period

The existing registered filing agent (RFA) would transition to CSP and be granted registration as a CSP to perform filing for their clients, until the expiry date of their current RFA registration. Non-registered RFAs must register with ACRA as CSP within six months of the CSP Act’s commencement on 9 June 2025.

2. Nominee Director and Shareholder Requirements

The CSP Regulations 2025 also addresses the issue of nominee directors, individuals who act as directors on behalf of others. Under the new regulations, persons are prohibited from acting as nominee directors by way of business unless their appointments are organized by registered CSP. Additionally, these CSP must assess the nominee directors as fit and proper for their roles. This ensures that only qualified individuals serve as nominee directors, reducing the risk of misuse and enhancing corporate governance.

Determine Whether the Person is Fit and Proper

CSP should assess whether a person is fit and proper at the time of arrangement based on their criminal record, bankruptcy Status, conduct history, competency and capacity, etc, and periodically refresh the assessment to ensure that the directors remain fit and proper after the appointment.

Another significant aspect of the new CSP Regulations is the requirement for nominee directors and nominee shareholders to disclose their nominee status and the identities of their nominators to ACRA. This increased transparency is intended to prevent the concealment of true ownership and control, thereby enhancing the integrity of corporate structures in Singapore.

3. AML/CFT/CPF Obligations for Corporate Service Providers (CSP)

Registered CSP must now adhere to stringent duties and responsibilities for Anti-Money Laundering, Countering the Financing of Terrorism, and Countering Proliferation of Weapons of Mass Destruction (AML/CFT/CPF) set under Part 4 of the CSP Regulations 2025 and under the Guidelines for Registered CSP. Key AML/CPF/CFT obligations includes:

i. Risk Assessments

CSP must take appropriate steps to identify, assess, and understand money laundering, terrorism financing, and proliferation financing (ML/TF/PF) risks, on a risk-sensitive basis, related to

Customers;
Countries or territories their customers are from or in, and where the CSP operates;
Products, corporate services; and
Transactions they undertake.

These steps include documenting risk assessments, considering all relevant risk factors to determine the overall risk level and appropriate mitigation measures, keeping assessments up to date, and providing them to ACRA upon request.

ii. Customer Due Diligence (CDD) Measures

A registered CSP must perform CDD measures before providing corporate services to a customer, when the registered CSP has reason to suspect ML/TF/PF, or doubts the veracity or adequacy of information obtained from earlier CDD measures.

a. Identification and Verification of Customer Identity
CSP must establish and verify the identities of customers, their agents, and beneficial owners (including directors, sole proprietors, partners, managers, or executive authorities for companies), using reliable and independent sources (such as SentroWeb®). It is essential to retain copies of all relevant documents during this process. The specific information that must be collected includes:

Full name and any alias;
Identification numbers (e.g., NRIC, passport, or incorporation number);
Residential or business address, contact number;
Date of birth or incorporation; and
Nationality or place of incorporation

b. Customer Screening
CSP must screen customers, agents, connected parties, and beneficial owners against any lists and information provided by ACRA, other directed sources to identify designated persons or terrorists, as defined under the United Nations Act 2001 and the Terrorism (Suppression of Financing) Act 2002. All screening results and determinations must be properly documented.

c. Simplified and Enhanced Customer Due Diligence (CDD) Measures
CDD measures must be performed on a risk-sensitive basis, tailored to the customer type, business relationship, product, service, or transaction, based on customer risk assessments.

Simplified CDD may be applied for low-risk customers, supported by documented risk assessments.
Enhanced CDD is required for higher-risk customers, including those involved in complex transactions, politically exposed persons (PEPs), or customers from high-risk jurisdictions. Measures like inquiring into transaction purpose, source of wealth and source of funds, as well as obtaining senior management approval are involved.

d. Remote Transactions
For customers not physically present for identification, CSP must implement additional measures to mitigate higher risks, including obtaining additional documents, and conducting and maintaining records of live video calls with director, member with at least 50% voting rights, or an authorized representative, to verify customer’s identity.

iii. Record‑Keeping

Comprehensive records of CDD, transactions, and risk assessments must be maintained for at least five years after the cessation of the business relationship with the customer, and should be made available to ACRA upon request.

iv. Ongoing monitoring

CSP must conduct ongoing monitoring of every business relationship with a customer to detect and prevent ML/TF/PF. This includes regularly reviewing customer activities and transactions to ensure they are consistent with the CSP’s knowledge of the customer and their risk profile.

Enhanced ongoing monitoring is required for higher-risk customers, which involves increased scrutiny, such as more frequent reviews or deeper analysis of business activity patterns.

v. AML/CFT/PF Internal policies, procedures and controls (IPPC)

CSP must develop, implement, and maintain adequate AML/CFT/PF internal policies, procedures (IPPC), and controls to identify and mitigate ML/TF/PF, according to the business size and the specific ML/TF/PF risks it faces.

The following matters must be covered:

CDD measures and ongoing monitoring;
Reporting;
Record‑keeping;
Risk assessment and management;
Audit of the internal policies, procedures and controls;
Monitoring and management of compliance
Hiring and training of employees; and
Customer screening

vi. Audit and Compliance Management

CSP are required to implement an independent and periodic audit function to assess the effectiveness of the internal AML/CFT/PF policies, procedures and controls, and compliance with regulatory requirements.

CSP should appoint a compliance officer in a management position to facilitate the compliance programme and management arrangements to ensure their effectiveness and up-to-date.

vii. Employees and Training

CSPs must implement screening procedures to hire fit and proper individuals as employees. Additionally, they should ensure that all employees receive training on regulations and knowledge related to AML/CFT/PF, as well as an understanding of the AML/CFT/PF internal policies, procedures.

viii. Reporting of Suspicious Transactions

A registered CSP must have procedures in place to report suspicious transactions, including persons, avenue, required information and timeline to report. The compliance officer or senior management should file a suspicious transaction report (STR) with the Suspicious Transaction Reporting Office (STRO) no later than five business days after establishing suspicion, or within one business day for higher-risk cases. Any reasons for non-filing must be documented. It’s important to note that CSPs should avoid any actions that may tip off the customers or parties involved.

STRO Online Notices and Reporting Platform (SONAR) for STR:
https://www.police.gov.sg/sonar

4. Increased Penalties for Non-Compliance

The CSP Act 2024 and CSP Regulations 2025 introduces higher penalties for non-compliance to ensure adherence to regulatory requirements. The following table summarizes the key penalties:

Breaches	Penalties
Failure to register with ACRA as a CSP	Fines up to S$50,000, imprisonment for up to two years, or both; additional fine up to $2,500 per day for continuing offense.
Breaches of AML/CFT/PF obligations	Fines up to S$100,000 per breach for CSP and their senior management.
Acting as a nominee director without arrangement by a registered CSP	Fines up to S$10,000.
Arranging for a person to act as a nominee director without ensuring they are fit and proper	Fines up to S$100,000.
Offences pertaining to registers of registrable controllers, nominee directors, and nominee shareholders	Fines ranging from S$5,000 to S$25,000.

How Corporate Service Providers (CSP) Can Prepare for the Corporate Service Providers Regulation Effective from 9 June 2025

CSP must take proactive steps to prepare for the impending legislation of the CSP Bill to ensure compliance and mitigate potential risks.

Step 1—Register with ACRA

If your entity provides corporate services, ensure it is registered with ACRA as a CSP before the deadline. Review ACRA’s Bizfile portal for registration procedures and requirements.

Step 2—Conduct a Compliance Gap Analysis

CSP should perform a comprehensive review of their current practices and policies to identify gaps related to registration, AML/CFT/PF, and other regulatory obligations. Internal policies, procedures, and controls should be updated accordingly to address any identified deficiencies.

Step 3—Strengthen Nominee Arrangements

CSP should review nominee director and shareholder arrangements to ensure compliance with fit-and-proper assessments and disclosure requirements, as well as update registers and file the necessary information with ACRA accordingly.

Step 4—Invest in Staff Training

It is also important to develop training programs for staff to enhance awareness of the new requirements and instil a culture of compliance within the organization.

Step 5—Leverage Technology Solutions

CSP are advised to adopt advanced AML/CFT software to streamline screening, CDD, ongoing monitoring, and risk assessment and mitigation. Automated solutions, such as SentroWeb® AML/CFT screening and CDD platform, can reduce manual errors and enhance efficiency.

Click here to learn how SentroWeb® help CSP enhance compliance

By taking these proactive measures, CSP can better position themselves to navigate the complexities of the regulatory requirements and foster trust with clients and regulators alike.

How Ingenique Solutions Can Help

At Ingenique, we specialize in providing trusted AML/CFT solutions tailored to the needs of Corporate Service Providers (CSP) in Singapore. Our comprehensive solutions and services empowers CSP to meet the requirements of the CSP Regulations and AML/CFT Guidelines with confidence.

Here’s how we can support you:

AML/CFT Internal policies, procedures and controls (IPPC) Template

If your CSP firm lacks internal AML/CFT Policies, Procedures, and Controls (IPPC) documents, or is uncertain how to develop or update one to align with the latest regulatory requirements, you can purchase a complete and customizable IPPC Template here. This resource can simplify compliance efforts and ensure that all essential protocols are effectively implemented.

SentroWeb® AML/CFT screening and CDD Solutions

CSP are also encouraged to implement technology solutions that streamline the AML/CFT/CPF compliance processes, such as screening platforms and automated reporting and monitoring systems.

One trusted technology solution designed for CSP in Singapore is SentroWeb® Corporate Secretarial and AML/CFT Solution. This platform allows you to manage comprehensive corporate secretarial tasks alongside anti-money laundering screening, customer due diligence (CDD), automated ongoing monitoring, and auditable recording and reporting functions. Click here to learn more.

Up to 50% PSG Funding Support for SentroWeb® before 7 September 2025

CPS SMEs in Singapore are now eligible for up to 50% Productivity Solutions Grant (PSG) support for the adoption of SentroWeb®, a Pre-Approved Solution under the IMDA SMEs Go Digital programme. Click here to learn more, book a free demo and get quotes for application before 7 September 2025.

Conclusion on New CSP Regulations 2025 in Singapore

The new CSP Bill marks a significant step forward in Singapore’s efforts to bolster corporate governance and compliance. By mandating registration, enforcing AML/CFT/CPF obligations, regulating nominee directors, enhancing disclosure requirements, and increasing fines, the legislation aims to create a more transparent and accountable corporate environment. These changes not only protect the integrity of the financial system but also reinforce Singapore’s reputation as a premier destination for international business.

As the implementation of the CSP Bill progresses, it will be crucial for corporate service providers and businesses to stay informed and compliant with the new regulations. In doing so, they will contribute to a safer, more transparent, and reputable corporate landscape in Singapore.

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Corporate Service Providers Act and Regulations 2025: A Guide for Singapore CSP